CITY AS LAB FONDATION,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS),MUMBAI, MUMBAI

ITA 2023/MUM/2024Status: DisposedITAT Mumbai30 October 2024AY 2024-25Bench: SHRI AMIT SHUKLA (Judicial Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the definition of 'education' under Section 2(15) is broad and not limited to formal schooling. It also found that the assessee did not charge fees from students or government schools, and the nominal fees from private schools did not indicate a profit motive.

What were the facts?

The assessee, City As Lab Foundation, applied for registration under Section 12AB and 80G of the Income Tax Act. The CIT(Exemptions) rejected the application, stating the assessee was not affiliated with any board/university and was providing education for a fee with a profit motive.

What were the issues?

Whether the assessee's activities qualify as 'education' under Section 2(15) and whether it operates with a profit motive.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G,Section 2(15)

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Cases cited in this judgment(4)Show list

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Income Tax Appellate Tribunal, ‘C’ BENCH

For Appellant: Shri. Nishant Thakkar &, Shri. Hiten Thakkar
For Respondent: Shri. Amol Kirtane (CIT DR)
Hearing: 22/10/2024Pronounced: 30/10/2024

PER AMIT SHUKLA (J.M): The aforesaid appeal has been filed by the assessee against separate order passed by ld. CIT(Exemption) Mumbai rejecting the application u/s.12AA and 80G vide order dated 22/02/2024. 2. The brief facts are that assessee company was incorporated under Companies Act, 2013 u/s.8(1) of the Companies Act. The assessee company was originally incorporated with the following objects:- i.

To promote the activities of research & development among the school children by enabling them to use their city as a lab

The order continues below.

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