{"id":236122,"date":"1982-10-21T00:00:00","date_gmt":"1982-10-20T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/st-josephs-upper-primary-school-vs-income-tax-officer-on-21-october-1982"},"modified":"2016-12-22T11:00:23","modified_gmt":"2016-12-22T05:30:23","slug":"st-josephs-upper-primary-school-vs-income-tax-officer-on-21-october-1982","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/st-josephs-upper-primary-school-vs-income-tax-officer-on-21-october-1982","title":{"rendered":"St. Joseph’S Upper Primary School vs Income-Tax Officer on 21 October, 1982"},"content":{"rendered":"
Income Tax Appellate Tribunal – Hyderabad<\/div>\n
St. Joseph’S Upper Primary School vs Income-Tax Officer on 21 October, 1982<\/div>\n
Equivalent citations: 1983 4 ITD 231 Hyd<\/div>\n
Bench: S Rajaratnam, K Thanikachallam<\/div>\n<\/p>\n
<\/pre>\n
ORDER<\/p>\n
S. Rajaratnam, Accountant Member <\/p>\n
1. This is an appeal filed by St. Joseph’s Upper Primary School,   Kurnool, objecting to the order of the AAC upholding partly the   assessment made on the assessee for the assessment year 1976-77.\n<\/p>\n
2. The assessee is a society registered under the Societies   Registration Act, 1860, on 9-5-1967. The objects of the society   are:\n<\/p>\n
(a)  to promote  educational  institutions and useful  knowledge in     St. Joseph's  Upper Primary School and other school or schools that   may be started by the Managing Body ;\n \n\n(b)  to  organise  and  develop the St.  Joseph's Upper Primary   School and other school or schools on approved lines. \n \n\n<\/pre>\n
The managing body consists of 7 persons. Though the name of the   society is Upper Primary School, it is ordinarily meant to cover   classes upto VII ; there had been an expansion in 1967 and there are X   classes run in English medium. The school is located in two buildings.   One belongs to Smt. S.C. Rojamma who is the headmistress and who is   also incidentally the daughter-in-law of the Founder-Secretary, Sri   Swamykannu Pillai. The other building is owned by the society. It was   the assessee’s case that its surplus income was exempt from tax under   Section 10(22) of the Income-tax Act, 1961 (‘the Act’). This claim was   negatived by the ITO on the ground that the assessee is a society which   runs the school, while according to him, it is only the school which is   entitled to be recognised as an institution within the meaning of   Section 10(22). He was also of the view that the assessee could not be   treated as an institution exempt under Section 11 of the Act,   notwithstanding registration under Section 12A of the Act because he   was of the view, that the assessee was doing it as a business and that   the school was run by an AOP consisting of the family members of   ShrijSwamykannu Pillai and that the induction of other the members was   merely ‘to give a colour of a public body’. So, he brought to tax an   amount of Rs. 54,503 which was the surplus during the year. He brought   a further amount of Rs. 22,000 as income from other sources on the   ground that the further construction of the building in the name of   Smt. Rojamma was not properly explained. The total income as computed   by the ITO was Rs. 76,500. The assessee in its appeal before the first   appellate authority resisted every conclusion, both legal and factual,   on the part of the ITO. The first appellate authority agreed with the   findings of the ITO except for the fact that he found material for the   deletion of Rs. 22,000 under the head ‘Other sources’ because,   according to him, if the construction was unexplained, it should be   considered in the hands of the lady and not the society as the building   belonged to her. He assumed that the property in the name of Smt.   Rojamma was purchased and improved entirely out of the funds of the   society. Since the school building did not belong to the society and   that it would revert to Smt. Rojamma in the event of dissolution, he   concluded that it was an educational institution for profit. He,   therefore, did not agree that the assessee was eligible for exemption   either under Section 10(22) or even under Section 11.\n<\/p>\n
3. The learned counsel for the -assessee claimed that there had been   number of mistakes made by the authorities below on facts. The school   is run in two buildings. One of them undoubtedly belongs to the   society. The other belongs to Smt, Rojamma. It was purchased by her and   the ground floor was constructed by her out of her own personal funds.   Her husband is a planter having considerable resources. All the same,   she had allowed the use of the property since the family was of   charitable disposition and was interested in running the English Medium   School which was in demand in that area. The ground floor was acquired   by her in 1970. It was only for the construction of first and second   floors that the lady borrowed funds from the society. The construction   was for the benefit of the school and she did not charge any rent   either for the ground floor or for the newly constructed first and   second floors. It was for this reason that the society had not charged   any interest on the advance made for construction of part of the   building. He also cited number of authorities for his claim that even   societies or trusts running a school will be eligible for being treated   as an institution. He also pointed out the Circular reproduced in one   of the Tribunal’s decisions in the case of Thiagarajar Educational   Trust v. ITO [1982] 8 Taxman 77 (Mad.-Trib.). The learned departmental   representative relied on the orders of the authorities below. He   pointed out that Section 10(22) does not automatically exempt every   educational institution but those ‘existing solely for educational   purposes and not for purposes of profit’. According to him, an   institution which was lending money to family members of the founder to   purchase property in their name could not be treated as such an   institution. He also claimed that the fact there was a surplus show   that the institution exists for making profit. He also relied upon the   other argument that a society running an institution is not the same as   the institution itself. Only the latter will be eligible for exemption.   He also relied on the other arguments found in the orders of the   authorities below.\n<\/p>\n
4. We have carefully considered the records as well as the   arguments. The objects of the society are reproduced in para 2 (supra).   Both the objects are merely to run the institution already running in   the name of St. Joseph’s Upper Primary School or any other school that   may be started by the managing body. In other words, the society has   educational purpose as its sole object. As for the first objection that   a society running institution cannot come under Section 10(22), we find   that this question had come up before various High Courts and these   High Courts have unanimously overruled the narrow view that is sought   to be adopted by the authorities in this case. The Orissa High Court in   Secondary Board of Education v. ITO [1972] 86 ITR 408, found that a   statutory authority could be treated as ‘other educational institution’   within the meaning of Section 10(22). The Allahabad High Court in Katra   Education Society v. ITO [1978] 111 ITR 420, held that a similar   society running an intermediate college has to be treated as an   educational institution. It observed that the word ‘institution’ has   not been defined in the Act and that there is no reason why a society   running an educational institution cannot be regarded as one. It   characterised the narrow interpretation sought to be adopted by the   authorities as ‘manifestly erroneous’. The Madras High Court in Addl.   CIT v. Aditanar Educational Institution [1979] 118 ITR 235 found that a   similar society registered under the Societies Registration Act, 1960   to run educational institution could be treated as an educational   institution itself under Section 10(22). We also have a decision of the   Andhra Pradesh High Court itself in the case of Governing Body of   Rangaraya Medical College v. ITO [1979] 117 ITR 284, where a similar   society registered under the Societies Registration Act to manage the   college was treated as an educational institution within the meaning of   Section 10(22). The High Court referred to an English decision in   Ereaut v. Girls Public Day School Trust Ltd. [1930] 15 TC 529 (HL),   where it was held that a limited company running a public school could   be treated as a ‘public school’ itself within the meaning of the UK   Income-tax Act. The Calcutta High Court in Birla Vidhya Vihar Trust v.   CIT [1982] 136 ITR 445, held that even a trust running educational   institutions, etc., for the benefit of the public would be eligible for   exemption under Section 10(22) and the surplus of income over   expenditure will not be liable for tax. While all these different High   Courts have taken the same view that a society with educational purpose   alone could be treated as an educational institution, the Board itself   seems to have accepted this view by their instruction No. 111 [(F. No.   194\/16\/1977 IT (A-I), dated 29-10-1977] in the following words:\n<\/p>\n
  However, there may be cases where the educational institutions may   be owned by trusts or societies to whom the provisions of Section 11   may be applicable. Where all the objects of these trusts are   educational and the surplus, if any, from running the educational   institutions is used for educational purposes only, it can be held that   the institution is existing solely for educational purposes and not for   purposes of profit.\n<\/p>\n
Instructions were issued in the context of the question of treatment   of a university or other educational institution within the meaning of   Section 10(22) or a hospital or other institution under Section   10(22\/A) and the instructions have been reproduced in full in another   decision of this Tribunal in Thiagarajar’s case (supra), a decision to   which one of us was a party. Since the object of the society is only   for educational purpose, and since the surplus, if any, cannot be   appropriated by any individual, the claim of the assessee is in   accordance with both the law as settled by the High Courts and the   instructions of the Central Board of Direct Taxes.\n<\/p>\n
5. It was sought to be argued that all is not well with this   institution. The school is housed in two buildings. One of the   buildings is owned by the society. The other belongs to Smt. Rojamma   who is the daughter-in-law of the secretary of the society and is also   the Headmistress in her own right. The authorities are wrong in   presuming that the entire purchase consideration was met by the   society. The plot and the ground floor was constructed by her out of   her own resources. The first and second floors were, however,   constructed by borrowing from the society. But the society had the   benefit of housing its school in the premises without paying rent. It   was for this reason that no interest was charged. No doubt, both   interest and rent were mutually charged from 1-4-1977. The learned   departmental representative tried to make out a point out of the fact   that the interest charged was less than the rent of Rs. 1,500 per month   fixed for the building. It is only because part of the loan had already   been repaid. So long as it is not shown that the interest charged was   less than the market rate or the rent paid by the society is more than   the market rent, we cannot assume that Smt. Rojamma had taken any undue   benefit. In other words, we are not in a position to say that there has   been any misuse of authority so as to make the society’s professed   objects as not being real. The learned departmental representative   tried to make out that the benefit makes the society a sham one and   that at any rate, the assessee will be deprived of the benefit of   exemption in view of Section 13 of the Act which will deprive of the   exemption in cases where founder enjoys benefit. Since we have not   found any benefit, we need not go into other arguments on behalf of the   taxpayer which are also, in our view, not untenable even otherwise as   no material have been brought on record to support the stand of the   revenue both on facts and on law. We will, therefore, not discuss the   issue further.\n<\/p>\n
6.  It has been sought to be suggested by the learned AAC that since   the regulations of the society attract the provisions of the Societies   Registration Act in the event of dissolution and since one of the   buildings is owned by the founder’s daughter-in-law, he has assumed   that in the event of dissolution the handing over of the building to   Smt. Rojamma would amount to private profit. The foundation on which   this inference is drawn is flimsy. If the property is handed over to   the real owner in the event of dissolution, it does not mean the assets   of the society  are  being distributed to the founder or his relatives.     Under the Societies Registration Act, the funds have to be utilised   for a similar purpose for running some other educational institution   and hence this is a case where assets or the surplus cannot be diverted   for any purpose other than the objects of the society. Stress was also   laid by the learned departmental representative on the point that the   assessee had made a profit and that Section 10(22) confines the benefit   only to institutions which are not run for profit. Here again, we are   not in a position to say that the institution  is run for purposes of   earning profit. There had been  loss in one year and surplus in   another. Besides, profit contemplated by the law is private profit and   not profit for the purpose of implementation of the basic objectives as   in this case.   In fact, the CBDT in the Circular already referred to   in  an earlier paragraph also makes it clear by pointing out that all   surplus will not be taxable unless there is diversion of such profit   for personal use in the following words:\n<\/p>\n
  If the profit of educational institution can be diverted for the   personal use of the proprietor thereof, then the income of the   educational institution will be subject to tax.\n<\/p>\n
7.  Hence, in any view of the matter, we do not   find any scope for   disallowance of the assessee’s claim for exemption under Section   10(22). The appeal is allowed and the assessment is annulled.<\/p>\n","protected":false},"excerpt":{"rendered":"
Income Tax Appellate Tribunal – Hyderabad St. Joseph’S Upper Primary School vs Income-Tax Officer on 21 October, 1982 Equivalent citations: 1983 4 ITD 231 Hyd Bench: S Rajaratnam, K Thanikachallam ORDER S. Rajaratnam, Accountant Member 1. This is an appeal filed by St. Joseph’s Upper Primary School, Kurnool, objecting to the order of the AAC […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[1],"tags":[],"class_list":["post-236122","post","type-post","status-publish","format-standard","hentry","category-judgements"],"yoast_head":"\nSt. Joseph'S Upper Primary School vs Income-Tax Officer on 21 October, 1982 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/st-josephs-upper-primary-school-vs-income-tax-officer-on-21-october-1982\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"St. Joseph'S Upper Primary School vs Income-Tax Officer on 21 October, 1982 - 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