Meaning of “Education”

The meaning of education under section 10(22), 2(15), 10(16) of the Income Tax Act is not defined in the act itself. But we can take guidance from decisions by various high courts. Here are excerpts of courts orders in which the Hon’ble High Court tried to explain the meaning of education.

meaning of education

Meaning of education defined by court

The phrase ‘education’ used in section 10(22) of the Income Tax Act came up before various high courts as detailed under :

1.Hon’ble Gujarat high court explained the meaning of ‘education’ while delivering judgment in CIT vs. Sorabji Nusserwanji Parekh [1993] 201 ITR 939 (Guj.) as under :

Meaning: What the word ‘education‘ connotes is the process of training and developing the knowledge, skill, mind and character of students by normal schooling.

2.Hon’ble supreme court explained the meaning of ‘education’ while delivering judgment in Sole trustee, loka shikshana trust vs. CIT [1975] 101 ITR 234 (SC) as under :

Section : 2(15)

Meaning: The word ‘education’ in section 2(15) connotes the process of training and developing the knowledge, skill, mind and character of students, by normal schooling, and has not been used in the wide and extensive sense according to which every acquisition of further knowledge constitutes education.

3.Hon’ble Delhi High Court explained the meaning of ‘education’ while delivering judgment in Delhi music society vs. Director general of income-tax [2012] 17 taxmann.Com 49/204 taxman 231 as under :

Section : 2(15)

Meaning : The supreme court in the case of sole trustee, loka sikshana trust v. Cit [1975] 101 ITR 234 interpreted the word ‘education’ in section 2(15) and held that the word has been used to denote systematic instruction, schooling or training given to the young in preparation for the work of life and it also connotes the whole course of scholastic instruction which a person has received. It has further been observed that the word also connotes the process of training and development of knowledge, skill, mind and character of students by normal schooling.

Where the petitioner is being run like any school or educational institution in a systematic manner with regular classes, vacations, attendance requirements, enforcement of discipline and so on, the petitioner meets the requirements of an educational institution within the meaning of section 10(23c)(vi).

4.Hon’ble Delhi High Court explained the meaning of ‘education’ while delivering judgment in Divya yog mandir trust vs. Jt. Cit [2013] 37 taxmann.Com 227/60 sot 154 (uro) (Delhi) as under :

Section : 2(15)

Meaning: Any form of educational activity involving imparting of systematic training in order to develop the knowledge, skill, mind and character of students, is to be regarded as ‘education’ covered under section 2(15). In view of above, it can be concluded that imparting of yoga training through well structured yoga shivir/camps falls under the category of imparting education which is, one of the charitable objects defined under section 2(15).

4. Hon’ble Andhra Pradesh High Court explained the meaning of ‘education’ while delivering judgment in R.R.M. Educational society vs. CCIT [2012] 20 taxmann.Com 269/208 taxman 81 (Mag.) as under :

Section : 2(15)

Meaning :The sense in which the word ‘education’ has been used in section 2(15) is the systematic instruction, schooling or training given to the young in preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received.

The word ‘education’, in section 2(15), has not been used in that wide and extended sense according to which every acquisition of further knowledge constitutes education. What education connotes, in that clause, is the process of training and developing the knowledge, skill, mind and character of students by formal schooling.

5. Hon’ble ITAT-Bombay explained the meaning of ‘education’ while delivering judgment in Dr. J.C.N. Joshipura vs. ACIT [1996] 56 itd 424 (Bom. – Trib.) as under :

Section :10(16)

Meaning : The word ‘education’ includes within its ken knowledge, understanding and reflection.

Section 10(22) of Income Tax Act

10(22). Omitted by the Finance (No. 2) Act, 1998, w.e.f. 1-4-1999;

In this article, you can get guidance from high courts on the meaning of education under section 10(22), 2(15), 10(16) of the Income Tax Act.

Updated up to Finance Act 2021

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