Shiksha Trust Vs CIT (ITAT Bangalore)
₹67.40 Crore Preschool Fees Raise Questions, but Four Days Is No Fair Hearing: Bangalore ITAT Restores 12AB Application
Summary: The assessee, Shiksha Trust, was a public charitable trust formed with the stated object of promoting education & running schools. It filed Form 10AB on 19 August 2025, seeking charitable registration. The Tribunal’s order initially refers to the application as one u/s 12AA, but its operative direction requires the assessee to establish eligibility for registration u/s 12AB.
The financial details initially furnished by the trust showed corpus of ₹1 lakh, other liabilities of ₹86,69,749 & other assets of ₹87,69,749. The trust reported nil receipts for the financial years ending in 2022 & 2023.
However, material subsequently examined by the CIT(E) indicated that the trust had commenced preschools during FY 2024-25 at Bangalore & in Ranga Reddy District, Telangana. The trust reportedly collected fees aggregating to ₹67,40,21,417.
The CIT(E) considered this amount abnormally high for preschool activities. According to him, the receipts required verification with reference to bank statements, number of students, fees charged per child & other supporting documents. In the absence of complete records, he formed a prima facie view that the activities appeared to be commercial operations carried on under the guise of education.
