This article provides an in-depth analysis of the Income Tax Appellate Tribunal’s decision regarding the Haryana State Remote Sensing Application Centre’s appeal against the order of CIT(Exemption), Chandigarh, which denied their application for registration under section 12AA of the Income Tax Act, 1961.
The Haryana State Remote Sensing Application Centre (HARSAC), established in 1986 under the Department of Science and Technology, Government of Haryana, is a society aimed at promoting research and development in the field of remote sensing. The society’s activities include providing educational and training facilities to researchers and students and conducting research analysis for various government organizations and departments.
The CIT(Exemption), Chandigarh denied HARSAC’s application for registration under section 12AA, citing that HARSAC does not qualify under the education category as defined under section 2(15) of the Income Tax Act. The decision was influenced by a previous Supreme Court ruling which narrowly defined ‘education’ as systematic instruction, schooling, or training given to the young in preparation for the work of life.
The article examines the tribunal’s decision, which overturned the CIT(Exemption)’s ruling based on broader interpretations of ‘education’ by various high courts and the Supreme Court in subsequent cases. These interpretations acknowledge that the dissemination of knowledge and training provided by professional bodies also constitutes education under the Act.
The tribunal’s decision to allow the appeal reinstates HARSAC’s status as a charitable educational institution, enabling them to claim exemptions under the Income Tax Act. This case sets a significant precedent for similar institutions engaged in research and training in specialized fields.
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