2022 (7) TMI 265

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.... for registration under section 12AA of the Act. 2. On the facts and circumstances of the case Id. CIT (Ex) has erred both on facts and in law in rejecting the application for registration under section 12AA of the Act, despite the assessee bringing all material and evidences on record. 3. On the facts and circumstances of the case Id. CIT (Ex) has erred both on facts and in law in rejecting the application for registration under section 12AA of the Act in view of an earlier application having been rejected, ignoring the fact that there is no law preventing the assessee to file a second application for registration under section I2AA of the Act. 4. On the facts and circumstances of the case Id. CIT (Ex) has erred both on facts and in ....

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....ction 2(15) of the Income Tax Act. 5. After this rejection, the assessee applied again on 02.11.2018 for registration u/s 12A of the Income Tax Act, 1961 and duly replied all the queries raised by the Ld. CIT(E), Chandigarh who again on 28.05.2019 passed the order of rejection u/s 12AA. The Ld. CIT(E) in the order stated that imparting skill development training doesn't partake the meaning of public charity. 6. Heard the arguments of both the parties and perused the material available on record. 7. Training means & constitutes a basic concept in human resource development. It is concerned with developing a particular skill to a desired standard by instruction and practice. Training is a highly useful tool that can bring a person into....

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....I wherein it was held that "the word 'education' is to be given wide interpretation which includes training and developing the knowledge, skill, mind and character of the students by normal schooling. 10. The issue before us stands covered by the following decisions:- a. RUBBER SKILL DEVELOPMENT COUNCIL (FORMERLY RUBBER SKILL DEVELOPMENT CENTRE) VERSUS DIT (E) , NEW DELHI (ITA No. 3216/DeI/2014) b. GEAR TRAINING AND RESEARCH FOUNDATION VERSUS CIT (EXEMPTION), JAIPUR (ITA. No. 49/JP/2021) c. CENTRAL INSTITUTE OF TOOL DESIGN, HYDERABAD VERSUS DIRECTOR OF INCOME-TAX (EXEMPTION), HYDERABAD (ITA No. 1563/Hy d/2014) 11. We also find that the Ld. CIT (E) has taken incorrect inference that total credit of Rs. 7.66 Crore during the f....