Where the assessee-trust was generating receipts from certification fees, membership fees and training programmes which were incidental to its main object of imparting education and skill development, and the assessee was not engaged in profit maximisation or charging disproportionately high fees, the activities could not be regarded as commercial activities but fell within “education” and were not hit by proviso to section 2(15).

13. (2026) 184 taxmann.com 634 (Chennai Trib)

DCIT vs. ICT Academy of Tamil Nadu

A.Y.: 2017-18

DATE: 25.03.2026

Section: 2(15)

Where the assessee-trust was generating receipts from certification fees, membership fees and training programmes which were incidental to its main object of imparting education and skill development, and the assessee was not engaged in profit maximisation or charging disproportionately high fees, the activities could not be regarded as commercial activities but fell within “education” and were not hit by proviso to section 2(15).

FACTS

The assessee was a society registered under section 12A and was engaged in activities relating to skill development, training, certification, and employability enhancement of students and faculty in coordination with Government bodies and educational institutions. It conducted structured training programmes, faculty development initiatives, and vocational courses aligned with national skill development policies. For AY 2017-18, the assessee filed its return of income declaring a total income as Nil after claiming