Sports Training Trust Eligible for Section 12AB & 80G

Case Details: Yakshit Yuva Foundation vs. Commissioner of Income-tax, Exemption [2026] 184 taxmann.com 245 (Panaji-Trib.)

Judiciary and Counsel Details

Pavan Kumar Gadale, Judicial Member & G. D. Padmahshali, Accountant Member
Shreepada Ravi Rao, Ld. AR for the Appellant.
Azar Zain, Ld. DR for the Respondent.

Facts of the Case

The assessee-trust was formed to impart taekwondo and self-defence training to students, including underprivileged girls in government schools. It also provided free training to underprivileged students. The trust applied for registration under section 12AB and approval under section 80G. The CIT(E) rejected the assessee’s applications for registration under sections 12AB and 80G on the ground that imparting sports training to students did not constitute ‘education’ within section 2(15). Aggrieved by the order, the assessee preferred an appeal to the Bangalore Tribunal.

ITAT Held

The Tribunal held that the registered trust’s principal object revolved around promoting and instilling the values of sportsmanship among the youngster, developing young athletes in taekwondo, and providing sports training to the children/students from rural and underprivileged class/areas. It was also noted that the appellant’s object was closely aligned with the national education policy announced by the central government of India in 2020.

It was obvious from the annual activity reports submitted for three years that the appellant trust had reached out to thousands of students to inspire and instil self-defence among underprivileged girls studying in government-aided schools. Thus, the assessee was organising its operation with much less commercial exploitation. The holistic vouching suggested that charging nominal fees from students in substance lacked commercial principle.

The term ‘education’ has been interpreted in the context of Section 2(15) by the Hon’ble Apex Court in Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC). The Hon’ble lordship therein held that what education connotes in clause 2(15) is the process of training and developing the knowledge, skill, mind, and character of students by normal schooling. It clearly emerges that so long as the assessee is engaged in developing any knowledge or skill or character of school/college-going students, such assessee’s activities of imparting scholastic training shall fall within the scope of ‘education’ for section 2(15).

In the instant case, the assessee was admittedly engaged in imparting and developing sports knowledge to school-going girls and underprivileged students, either in-house or through workshops. Thus, an activity of providing scholastic sports training and conducting incidental workshops was with a focal view to develop the sports knowledge, skills, mind & character of school students, which could fall within the realm of ‘education’ as used in section 2(15).

List of Cases Referred to

‘Shyam Sunder Sarma v. Pannalal Jaiswal (2005) 1 SCC 436 (para 11)
Sheodan Singh v. Daryao Kunwar AIR 1966 SC 1332 (para 11)
Dilip Kumar v. Esque Finamark (P.) Ltd. 2025 INSC 102 (para 12)
Al Jamia Mohammediyah Education Society v. CIT (Exemptions) [2024] 162 taxmann.com 114/298 Taxman 650/[2025] 482 ITR 41 (Bombay) (para 13)
CIT (Exemptions) v. A1 Jamia Mohammediyah Education Society [2025] 176 taxmann.com 761/481 ITR 215 (SC) (para 13)
Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) (para 18)
CoC v. Welkin Foods 2026 INSC 19 (para 19)
ACIT v. AUDA (2022) 115 CCH 253 (para 20)
CIT (Exemptions) v. Unique Educational Society [2024] 168 taxmann.com 448 (Punjab & Haryana) (para 21)
Deshpande Education Trust v. Asstt. CIT [2025] 181 taxmann.com 796/[2026] 309 Taxman 106 (Karnataka) (para 21)
ITO (Exemp.) v. Chembur Gymkhana [2017] 80 taxmann.com 354 (Mumbai)/[2017] 164 ITD 279 (Mumbai) (para 26)
Dahisar Sports Foundation v. ITO (Exemptions) [2017] 87 taxmann.com 313/167 ITD 710 (Mumbai) (para 26).