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Issues involved: Refusal of registration u/s 12AA of the Act to the assessee claiming to be an educational trust.
Summary: The appeal was against the Administrative Commissioner's order denying registration u/s 12AA of the Act to the assessee trust. The assessee claimed to be an educational trust established for educating tribal people by understanding their lifestyle and translating religious books into their language. The dispute arose as to whether the trust should be considered an educational or religious trust. The ld.representative for the assessee argued that the trust's main objective was educational, focusing on promoting literacy among tribal people through translating religious texts. On the other hand, the ld.DR contended that the trust primarily aimed at propagating the Christian religion, not conducting educational activities as defined u/s 2(15) of the Act. The Tribunal referred to previous judgments, including the Apex Court's decision in Sole Trustee, Loka Shikshana Trust v. CIT, which emphasized that education should involve systematic instruction through normal schooling. It was highlighted that mere coaching classes or translating religious texts did not qualify as education u/s 2(15) of the Act. Considering the arguments and precedents, the Tribunal concluded that the trust's activities did not align with the definition of education under the Act. It was noted that the trust's main objective was to promote the Christian religion, and no substantial educational activities were conducted. As the trust did not apply for registration as a religious trust u/s 12AA, the Tribunal upheld the denial of registration as an educational trust. In conclusion, the appeal by the assessee was dismissed, affirming the order of the Administrative Commissioner refusing registration u/s 12AA of the Act.
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