This case concerns a charitable trust engaged in conducting medical seminars, Continuing Medical Education (CME) programs, and professional training workshops for doctors and medical students. The Assessing Officer denied exemption under Sections 11 and 12 on the ground that such activities did not constitute “education” as defined in Section 2(15), arguing that the trust was not running a formal educational institution. On appeal, the CIT(A) held that the trust’s activities were academic and educational in nature. The Revenue challenged this before the ITAT. The Chennai Bench of the ITAT examined whether structured medical seminars and professional training programs qualify as imparting “education” and whether the trust is consequently eligible for exemption under Section 11.
Facts of the Case
The assessee was a charitable trust registered under Section 12AA of the Income-tax Act.
Its primary activity involved conducting medical seminars, workshops, conferences, and training sessions for practicing doctors, postgraduate students, and medical professionals.
The trust claimed exemption under Sections 11 & 12, declaring that these activities constituted “education” as per Section 2(15).
The Assessing Officer denied the exemption on the ground that:
The trust was not running a formal school/college.
The seminars were only for qualified doctors and did not amount to “systematic instruction”.
The activity was akin to providing services to professionals and therefore “commercial”.
The CIT(A) allowed the exemption holding that the activities were educational in nature.
The Revenue appealed before the ITAT.
Issues Before the ITAT
Whether conducting medical seminars, conferences, CME (Continuing Medical Education) programs for doctors amounts to imparting “education” under Section 2(15).
Whether the trust is eligible for exemption under Section 11 for such activities.
Whether the nature of activities amounted to commercial services to professionals.
Arguments by the Revenue
The trust was not running any educational institution affiliated to a university or medical board.
Seminars and conferences are not equivalent to regular courses or structured educational programs.
Training doctors enhances professional skills and is therefore not charitable but profit-oriented.
Registration under Section 12AA alone does not guarantee Section 11 benefits.
Arguments by the Assessee
The trust’s core objective is to advance medical knowledge and improve public healthcare indirectly by training doctors.
Continuing Medical Education (CME) is mandatory for doctors and is recognized by medical councils as formal education.
Fees received were nominal and only for cost recovery.
No profits were distributed, and any surplus was applied towards charitable objectives.
Activities are systematic, structured, and purely academic.
ITAT’s Findings
The term “education” under Section 2(15) is not limited to schools or colleges; it also covers structured programs that disseminate knowledge in a systematic manner.
Medical conferences and seminars conducted with academic content constitute imparting education.
Activities were aimed at professional development, which in turn promotes public health ― a recognized charitable object.
Fees charged were minimal and only covered expenses; there was no commercial motive.
There was full compliance with Section 11:
Proper books of accounts
Application of income on charitable purposes
No violation of Section 13
Thus, the trust satisfied the charitable purpose test as well as the application of income test.
Decision
Exemption under Section 11 allowed.
Conducting medical seminars and CME programs for doctors amounts to imparting education and falls within the charitable category under Section 2(15).
Revenue’s appeal dismissed.
Conclusion
The ITAT reinforced that specialized educational activities, including professional training and seminars, qualify as education for the purpose of Section 2(15).
Since the trust operated without profit motive and engaged in systematic dissemination of medical knowledge, it was rightfully eligible for exemption under Sections 11 and 12.