Registration Denied to Gurukulam Trust Imparting Informal Learning: ITAT Chennai
- Harshita Joshi and Dohit Muranjan
- 5 days ago
- 2 min read
Case: Agastya Gurukulam Public Charitable Trust v. Commissioner of Income-tax (Exemptions)
Court: ITAT Chennai
Assessment Year- N/A (Application for Registration under Section 12AB)
ITA No.: 376 & 377 (Chny) of 2025
Date of Order: 26th September, 2025
Brief Facts:
The assessee was a public charitable trust with the stated objects of relief of the poor and education.
It applied for registration under Section 12AB of the Income-tax Act, 1961.
The Commissioner (Exemptions) denied registration on the grounds that the trust was not conducting formal education or scholastic learning recognised by any authority, but was merely providing training without a systematic curriculum.
Further, the Commissioner also observed that no activities amounting to “relief of the poor” were carried out and that fees were being collected from students without scholarships or concessions.
Observations of the Tribunal:
The Tribunal noted that the assessee’s activities failed to meet the judicially established test of “education” as defined under Section 2(15) of the Act.
Relying on Sole Trustee, Loka Shikshana Trust v. CIT (1975) and New Noble Educational Society v. Chief CIT (2022), it reiterated that “education” for income-tax purposes means formal scholastic instruction involving structured learning and recognised curriculum.
Moreover, the Gurukulam model followed by the assessee though culturally significant did not align with the narrow and statutory meaning of “education” envisaged in the Income-tax Act.
The Tribunal also agreed with the Commissioner that mere training or home-schooling without accreditation or recognition cannot qualify as formal education.
Hence, the ITAT held that, since the assessee-trust was not engaged in providing formal scholastic education or recognised charitable activities, it failed to satisfy the conditions laid down under Section 12AB. Accordingly, the rejection of registration by the Commissioner (Exemptions) was upheld.
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