Charitable activities undertaken by assessee were found to be educational in nature despite receiving...

Charitable activities undertaken by assessee were found to be educational in nature despite receiving fees and corporate donations. Activities were systematic, with curated courses designed for skilling and educating students, fulfilling essential ingredients of formal education. Corporate receipts were mainly from CSR obligations, utilized solely for educational purposes. Affiliation with regulatory authority not essential for education u/s 2(15) as per Supreme Court precedents. Assessee's centers approved by NSDC, a nodal agency for vocational and technical training. Imparting education through virtual mode or new technologies does not detract from structured education if formal systematic process followed. Tribunal correctly held assessee's activities as educational u/s 2(15). .....

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