Page 170 - GSTL_2nd July 2020 _Vol 38_Part 1

88 GST LAW TIMES [ Vol. 38
24. The Oxford Dictionary of English (Third Edition) assigns the mean-
ing of the word “education” as follows :-
‘education-noun [mass noun] 1 the process of receiving or giving systematic
instruction, especially at a school or university : a course of education.  the
theory and practice of teaching : colleges of education.
 [count noun] a body of knowledge acquired while being educated : his
education is encyclopedic and eclectic.  information about or training in a
particular subject : health education.’
25. Chambers English Dictionary assigns the meaning of the word “ed-
ucation” as follows :-
‘Educate ed’u-kat, v.t. to bring up and instruct; to teach; to train, -adj
ed’ucable. - ns. Educabil’ity; educatabil’ity; education bringing up or training,
as of a child : instruction : strengthening of the powers of body or mind :
culture.’
26. Encyclopedia, Edited by David Crystal assigns the meaning of the
word “education” as follows :-
“Education what takes place when human beings learn something, often
from others but sometimes for themselves. It may happen during the day in
specially constructed buildings with qualified teachers following struc-
tured, approved courses based on books, equipment, or activities, or more
informally away from institutions in homes, streets, or meeting places. It is
not confined to traditional school subjects such as mathematics or history,
though these will usually constitute an important part of it, nor is it offered
only by paid teachers, for parents and elder brothers and sisters may well
play a central part in it. Increasingly, education is seen as something which
should develop the whole person, not just as a narrow academic training.
Thus in a vast variety of locations around the world, from lavishly
equipped buildings with the latest laboratory equipment to simple huts in
poorer countries, children and adults are learning the basic skills of read-
ing, writing, and arithmetic, developing qualities which will be valuable in
adult life whether at home or work, and in many cases taking retraining
courses because the job for which they originally prepared has been trans-
formed.”
27. It is, therefore, clear that the word “education” has a wide meaning
and includes the practice of teaching or training in a particular subject. The adju-
dicating authority, even after noticing that education apart from the process of
teaching and learning includes training in a particular subject, erred in observing
that ‘education’ is different from ‘training’. In this connection what is important
to notice is that the exemption is “in relation to education”. It cannot be doubted
that the activity conducted by the appellant is ‘in relation to education’ and,
therefore, the appellant would clearly be entitled to the benefit of the exemption
Notification dated 10 September, 2004.
28. In this connection it would be appropriate to refer to the decision of
the Tribunal in Sunbeam Infocomm Pvt. Ltd. wherein even though education in
Information Technology was conducted through authorized training centres
throughout the State of Maharashtra, but the appellant therein was only an au-
thorized agency for supplying books of various courses, creation of authorized
training centres, supervision of authorized training centres, collection of fees for
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