Medical Conferences Are “Education” Too: Chennai ITAT Revives 80G Approval of Cardiology Association

G. Prathap Kumar Vs CIT (Exemption) (ITAT Chennai)

Medical Conferences Are “Education” Too: Chennai ITAT Revives 80G Approval of Cardiology Association

In an important ruling on the scope of “education” under the Income-tax Act, the Chennai ITAT set aside the rejection of 80G renewal granted to CSI Chennai Chapter, a society engaged in promoting cardiovascular research and conducting medical conferences, seminars, workshops, and training programmes. The CIT(Exemptions) had denied renewal under Section 80G by holding that such activities did not fall within “education”, “medical relief”, or “relief to the poor” under Section 2(15).

The CIT(E) had further alleged that the association was functioning on principles of mutuality, catering mainly to members, and that receipts from sponsorships, delegate fees, workshops, and subscriptions were quid pro quo commercial receipts rather than charitable contributions. It was also alleged that the Memorandum permitted activities outside India, allegedly violating Section 11 requirements.

The Tribunal, however, observed that issues relating to applicability of Section 2(15) are matters normally examined during assessment proceedings and not conclusively at the stage of grant or renewal of registration. Importantly, the ITAT accepted the argument that systematic dissemination of specialized medical knowledge through seminars, conferences, and technical training programmes could fall within the ambit of “education”.

Relying heavily on its earlier decision in Neuro Update Chennai vs ITO, as well as judgments including Ahmedabad Management Association and Anesthesia Society, the Tribunal reiterated that “education” under Section 2(15) is not confined merely to formal classroom instruction but also includes continuing professional education and scientific knowledge dissemination. The matter was therefore remanded back to the CIT(E) for fresh adjudication after properly considering the judicial precedents relied upon by the assessee

FULL TEXT OF THE ORDER OF ITAT CHENNAI

The captioned appeal filed by the assessee challenging the order dated 27.06.2025 passed by the Ld. Commissioner of Income Tax (Exemptions), Chennai [hereinafter referred to as “Ld. CIT(E)”] in Form No. 10AD, whereby the application filed by the assessee in Form No. 10AB dated 08.10.2024 seeking renewal of approval under clause (iii) of the first proviso to Section 80G(5) of the Income-tax Act, 1961 [hereinafter referred to as “the Act”] came to be rejected.

2. Brief facts: The assessee, namely CSI Chennai Chapter, is a Society/Association established in the year 2001 with the principal object of promoting scientific knowledge and research relating to the cardiovascular system, including the development of preventive measures and treatment methodologies for cardiovascular diseases. In furtherance of its stated objects, the assessee has been conducting conferences, seminars, discussions, and training programmes at various centres on a periodic basis. The assessee was initially granted approval u/s. 80G of the Act vide order dated 24.09.2007 under the erstwhile regime, which was thereafter renewed for a further period of three years vide order dated 07.04.2022. Upon the expiry of the said approval period, the assessee filed an application in Form No. 10AB on 08.10.2024 under clause (iii) of the first proviso to Section 80G(5) of the Act seeking renewal of approval. Pursuant to notices issued by the Ld.CIT(E), the assessee furnished detailed replies along with supporting documents on 18.03.2025 in response to the questionnaire dated 17.02.2025 and subsequently on 23.04.2025 in response to the Show Cause Notice dated 17.04.2025. Further, the ld.AR of the assessee appeared before the Ld.CIT(E) on 18.06.2025 and advanced oral submissions. The Ld.CIT(E), by the impugned order dated 27.06.2025, rejected the application of the assessee broadly on four grounds. Firstly, it was held that the activities carried on by the assessee do not fall within the ambit of “relief to the poor”, “education”, or “medical relief” as contemplated u/s. 2(15) of the Act. In arriving at such conclusion, reliance was placed on the judgments of the Hon’ble Supreme Court in Sole Trustee, LokaShikshana Trust v. CIT and New Noble Educational Society v. CCIT, wherein the term “education” was interpreted in a restricted sense as referring to systematic schooling and formal instruction. According to the Ld.CIT(E), the activities undertaken by the assessee, such as organizing conferences and workshops, did not satisfy the said requirement. Secondly, the Ld.CIT(E) invoked the principle of mutuality on the ground that the objects and activities of the Society were primarily directed towards its members and not towards the public at large, and accordingly concluded that the activities amounted to advancement of members’ interests rather than charitable purposes within the meaning of Section 2(15) of the Act. Thirdly, the Ld.CIT(E) observed that receipts arising from conference sponsorships, delegate fees, membership subscriptions, and fees collected from workshops and training programmes were not in the nature of voluntary contributions, but represented consideration received on a quid pro quo basis, particularly since members derived identifiable benefits in return for such payments. Fourthly, it was held that the Memorandum of Association of the assessee envisaged activities beyond India, which according to the Ld.CIT(E), was inconsistent with the requirement u/s. 11(1)(a) of the Act mandating application of income for charitable purposes within India, thereby disentitling the assessee from approval u/s. 80G of the Act.

3. The Ld. Authorized Representative (“Ld. AR”) appearing on behalf of the assessee assailed the impugned order as being unsustainable both in law and on facts. With regard to the finding relating to “education”, the Ld. AR submitted that the Ld.CIT(E) had adopted an unduly restrictive interpretation of the expression. It was contended that the systematic conduct of seminars, conferences, workshops, and technical training programmes for cardiac surgeons, aimed at enhancing the quality of medical treatment for the ultimate benefit of the public, squarely falls within the scope of “education” u/s. 2(15) of the Act. Reliance was placed on the decision of the Co-ordinate Bench in Neuro Update Chennai vs ITO, wherein it was held that the term “education” u/s. 2(15) is not confined merely to formal scholastic instruction but also extends to the systematic dissemination of knowledge and specialized training.

4. Per contra, the Ld. Departmental Representative (“Ld. DR”) supported the impugned order and submitted that the rejection of the application was justified in law. It was contended that the activities of the assessee were essentially member-centric and that the receipts in the form of conference fees, sponsorship amounts, and membership subscriptions constituted quid pro quo arrangements devoid of any charitable character. The Ld.DR further submitted that the activities carried on by the assessee did not satisfy the judicially settled interpretation of the term “education” as laid down by the Hon’ble Supreme Court in Sole Trustee, LokaShikshana Trust v. CIT[101 ITR 234 SC] and New Noble Educational Society v. CCIT, and therefore the Ld. CIT(E) had rightly rejected the application.

5. We have carefully considered the rival submissions advanced by both parties and perused the material available on record, including the impugned order passed by the Ld.CIT(E) dated 27.06.2025, the paper book filed by the assessee containing the Memorandum of Association, details of registrations and approvals, financial statements for the relevant assessment years, replies submitted before the Ld. CIT(E), and the judicial precedents relied upon before us.

6. The principal issue arising for consideration before us pertains to the scope and extent of enquiry permissible by the CIT(Exemptions), Chennai while considering an application for renewal of approval u/s. 80G of the Act. On a plain reading of the impugned order, it is evident that one of the findings recorded by the Ld.CIT(E) relates to the applicability of Section 2(15) of the Act. In our considered opinion, the applicability of Section 2(15) is a matter that falls for examination during the course of assessment proceedings and not at the stage of grant or renewal of registration. Insofar as the issue relating to the activities constituting “education” is concerned, the Ld.AR had strongly contended that the expression ought to receive a broader and purposive interpretation, placing reliance on the judgments of the Hon’ble Madras High Court as well as the Co-ordinate Bench of the Tribunal. We have examined the nature of activities undertaken by the assessee, which essentially involve imparting specialized knowledge through seminars, workshops, and training programmes. In this context, reliance was placed on the decision of the Co-ordinate Bench in Neuro Update Chennai vs ITO [ITA No.1480/Chny/2025 dated 30.10.2025], wherein, under similar circumstances, the Tribunal had held as under:

“15. The core question before us is whether such activities constitute “education” within the meaning of section 2(15) of the Act, or whether they are commercial activities falling within the mischief of the proviso.

16. The expression “education” in section 2(15) has been interpreted liberally by various judicial authorities to include not merely formal schooling but also systematic dissemination of knowledge through seminars, workshops, and continuing education programmes.

17. The Hon’ble Gujarat High Court in Ahmedabad Management Association (supra) held that conducting management development programmes, public talks, and conferences amounts to educational activity. Similarly, in CIT (Exemption) v. Anesthesia Society [2019] 101 taxmann.com 227 (Rajasthan)/[2019] 260 Taxman 375 (Rajasthan), the Rajasthan High Court held that organising medical seminars and research conferences constitutes charitable activity even if primarily attended by medical professionals.

18. Applying the same principle, we hold that the assessee’s activities in organising neurology conferences and workshops squarely fall within the ambit of “education” u/s. 2(15).”

7. Having regard to the ratio laid down by the Co-ordinate Bench of the Tribunal in the aforesaid decision, we are of the considered view that the matter requires fresh examination at the hands of the Ld.CIT(E). Accordingly, in the interest of justice, the issue is remanded to the file of the Ld. CIT(E) for denovo consideration after affording adequate opportunity of being heard to the assessee and upon duly considering the judicial precedents relied upon by the appellant.

8. In the result, the impugned order passed by the Ld. CIT(E) is hereby set aside and the matter is restored to the file of the Ld. CIT(E) for fresh adjudication in accordance with law and in the light of the observations made hereinabove. The assessee is also directed to appear before the Ld. CIT(E) and furnish all requisite details and supporting materials for proper consideration of the matter. Consequently, the appeal filed by the assessee stands allowed for statistical purposes.

9. In the result, appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in the court on 21^st May, 2026 at Chennai.