CIT(E), Bangalore v. Ohio University Christ College

408 ITR 352High Court2018#4624 most cited

What is CIT(E), Bangalore v. Ohio University Christ College authority for?

Application of income for charitable purposes 'in India' is the relevant criterion, not whether the expenditure was incurred within or outside India. If income is applied for charitable activities outside India, it does not automatically mean the charitable activities themselves were conducted outside India.

26

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2019 to 2025.

Also referred to as

CIT v Ohio University Christ College · section 11(1)(a) · application of income in India · charitable activities outside India · faculty teaching charges · academic expenses · 408 ITR 352

Also reported as

99 Taxmann.com 377

Sections most often in play

Section 2(15)Section 11(1)(a)Section 12AASection 11Section 148Section 11(1)Section 12AA(3)Section 12A

Issues it is cited on

section 12aa(3)section 11(1)(a)section 11(1)accumulation of incomesection 11(2)application of incomesection 2(15)registration under section 12asection 12aachildsection 12acapital expenditure

Judgments citing CIT(E), Bangalore v. Ohio University Christ College

THE INSTITUTE OF CHARTERED SHIPBROKERS,CHENNAI vs. ITO, EXEMPTIONS WARD-2, CHENNAI

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1931/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 Sept 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…ded that in similar situation the Hon’ble Karnataka High Court has decided the controversy in favour of the assessee. He has referred the Judgment of the Hon’ble Karnataka High Court in the case of CIT(E), Bangalore Vs. Ohio University Christ College [2018] 408 ITR 352/[2018] 99 taxmann.com 377. He further contended that the order of the coordinate Bench of the Tribunal in assessee’s own has held that the assessee continues to enjoy the registration u/s 12AA, as if there was no interruption. He has filed the order of the coordinate Bench in assessee’s own case titled ‘The Institute of Chartered Shipbrokers, Ma…

THE INSTITUTE OF CHARTERED SHIPBROKERS,CHENNAI vs. ITO, EXEMPTIONS WARD-2, CHENNAI

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1930/CHNY/2025[2012-13]Status: DisposedITAT Chennai29 Sept 2025AY 2012-13

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…ded that in similar situation the Hon’ble Karnataka High Court has decided the controversy in favour of the assessee. He has referred the Judgment of the Hon’ble Karnataka High Court in the case of CIT(E), Bangalore Vs. Ohio University Christ College [2018] 408 ITR 352/[2018] 99 taxmann.com 377. He further contended that the order of the coordinate Bench of the Tribunal in assessee’s own has held that the assessee continues to enjoy the registration u/s 12AA, as if there was no interruption. He has filed the order of the coordinate Bench in assessee’s own case titled ‘The Institute of Chartered Shipbrokers, Ma…

THE INSITUTE OF CHARTERED SHIPBROKERS,,CHENNAI vs. ITO, EXEMPTIONS WARD-2,, CHENNAI

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1929/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Sept 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…ded that in similar situation the Hon’ble Karnataka High Court has decided the controversy in favour of the assessee. He has referred the Judgment of the Hon’ble Karnataka High Court in the case of CIT(E), Bangalore Vs. Ohio University Christ College [2018] 408 ITR 352/[2018] 99 taxmann.com 377. He further contended that the order of the coordinate Bench of the Tribunal in assessee’s own has held that the assessee continues to enjoy the registration u/s 12AA, as if there was no interruption. He has filed the order of the coordinate Bench in assessee’s own case titled ‘The Institute of Chartered Shipbrokers, Ma…

M/S. THE INSTITUTE OF CHARTERED SHIPBROKERS,CHENNAI vs. ITO, EXEMPTIONS WARD-3,, CHENNAI

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1928/CHNY/2025[2008-09]Status: DisposedITAT Chennai29 Sept 2025AY 2008-09

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…ded that in similar situation the Hon’ble Karnataka High Court has decided the controversy in favour of the assessee. He has referred the Judgment of the Hon’ble Karnataka High Court in the case of CIT(E), Bangalore Vs. Ohio University Christ College [2018] 408 ITR 352/[2018] 99 taxmann.com 377. He further contended that the order of the coordinate Bench of the Tribunal in assessee’s own has held that the assessee continues to enjoy the registration u/s 12AA, as if there was no interruption. He has filed the order of the coordinate Bench in assessee’s own case titled ‘The Institute of Chartered Shipbrokers, Ma…

M/S. THE INSTITUTE OF CHARTERED SHIPBROKERS,,CHENNAI vs. ITO, EXMEPTIONS WARD-1,, CHENNAI

In the result, all the appeals filed by the assessee are allowed in terms of our order as above

ITA 1927/CHNY/2025[2007-08]Status: DisposedITAT Chennai29 Sept 2025AY 2007-08

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1927, 1928, 1929, 1930 & 1931/Chny/2025 िनधा=रण वष= /Assessment Years: 2007-08, 2008-09, 2010-11, 2012-13 & 2013-14

For Appellant: Shri Y. Sridhar, FCAFor Respondent: Ms. R. Anitha, Addl. CIT
Section 11Section 11(1)Section 12ASection 2(15)

…ded that in similar situation the Hon’ble Karnataka High Court has decided the controversy in favour of the assessee. He has referred the Judgment of the Hon’ble Karnataka High Court in the case of CIT(E), Bangalore Vs. Ohio University Christ College [2018] 408 ITR 352/[2018] 99 taxmann.com 377. He further contended that the order of the coordinate Bench of the Tribunal in assessee’s own has held that the assessee continues to enjoy the registration u/s 12AA, as if there was no interruption. He has filed the order of the coordinate Bench in assessee’s own case titled ‘The Institute of Chartered Shipbrokers, Ma…

ADITYA BIRLA EDUCATION TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 4474/MUM/2025[NA]Status: DisposedITAT Mumbai19 Sept 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Saurabh Soparkar (virtually appear), Shri Yogesh Thar, ShriFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)

…on following judgments in support of certain legal propositions as under: a. Proposition 1: Application of income 'for the purposes in India' is relevant and not 'expenditure incurred within or outside India'. CIT(E) v. Ohio University Christ College [2018] 408 ITR 352 (Karnataka HC). In this case, the question before the Hon’ble Karnataka High Court was as follows: 11 Aditya Birla Education Trust “(1) Whether on the facts and in circumstances of the case, the Tribunal is right in deleting faculty teaching charges to Ohio University towards academic expenses by holding that merely because the payments are made…

NATIONAL CHILDRENS FUND S5, SIRI INSTITUTIONAL AREA, HAUZ KHAS NEW DELHI,NEW DELHI vs. THE INCOME TAX OFFICER WARD EXMP 2(4) DELHI, DELHI

In the result, both the appeals are allowed

ITA 3192/DEL/2023[2017-2018]Status: DisposedITAT Delhi28 Aug 2024AY 2017-2018

Bench: the appeal is finally heard or disposed off.”

Section 11(2)Section 12A

…ntions, the Ld. Counsel placed reliance on the following decisions:- a). Bochasanwasi Shri Akshar Purshottam Public cable Trust [2019] 105 taxmann.com 97 (SC) b) Market Committee, Tohana [2011] 12 taxmann.com 252 (P&H) c) Ohio University Christ College [2018] 408 ITR 352 (Karnataka) d) NBIE Welfare Society[2015] 54 taxmann.com 196 (Delhi) e) Bharat Kalyan Pratisthan [2007] 160 Taxman 216 (Delhi) f)Gurudwara Godri Sahib Baba Farid Society [2023] 154 taxmann.com 503 (Chandigarh-Trib.) g) Rogi Kalyan Samiti [2017] 88 taxmann.com 344 (Chandigarh- Trib.) h)Arhatic Yoga Ashram Management Trust [2021] 126 taxmann.com 76…

NATIONAL CHILDRENS FUND 5 SIRI INSTITUTIONAL AREA, HAUZ KHAS NEW DELHI,NEW DELHI vs. THE INCOME TAX OFFICER WARD EXEMPTION 2(4) DELHI, DELHI

In the result, both the appeals are allowed

ITA 3156/DEL/2023[2016-2017]Status: DisposedITAT Delhi28 Aug 2024AY 2016-2017

Bench: the appeal is finally heard or disposed off.”

Section 11(2)Section 12A

…ntions, the Ld. Counsel placed reliance on the following decisions:- a). Bochasanwasi Shri Akshar Purshottam Public cable Trust [2019] 105 taxmann.com 97 (SC) b) Market Committee, Tohana [2011] 12 taxmann.com 252 (P&H) c) Ohio University Christ College [2018] 408 ITR 352 (Karnataka) d) NBIE Welfare Society[2015] 54 taxmann.com 196 (Delhi) e) Bharat Kalyan Pratisthan [2007] 160 Taxman 216 (Delhi) f)Gurudwara Godri Sahib Baba Farid Society [2023] 154 taxmann.com 503 (Chandigarh-Trib.) g) Rogi Kalyan Samiti [2017] 88 taxmann.com 344 (Chandigarh- Trib.) h)Arhatic Yoga Ashram Management Trust [2021] 126 taxmann.com 76…

M/S. KSRTC PASSENGERS ACCIDENT RELIEF FUND TRUST,BANGALORE vs. INCOME TAX OFFICER (EXEMPTIONS), WARD-1, BENGALURU

In the result, appeals filed by the assessee for both the years under consideration stands allowed

ITA 374/BANG/2023[2014-15]Status: DisposedITAT Bangalore28 Aug 2023AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Joseph Varghese
Section 11

…ed by authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. 9.5 The Ld.AR had relied on the decision of Hon'ble Karnataka High Court in case of CIT(E) vs. Ohio University Christ College reported in 408 ITR 352 wherein Hon’ble Court considered the question as to whether, for the purposes of allowing exemption u/s. 11(1)(a) of the act, the income has to be “applied” or “spent”. The Hon’ble Court took the view that the word, “applied” as a wider connotation. In that case, the Hon'ble High Court held that provision for expenditure made in a particular year…

M/S. KSRTC PASSENGERS ACCIDENT RELIEF FUND TRUST,BANGALORE vs. INCOME TAX OFFICER (EXEMPTIONS), WARD-1, BENGALURU

In the result, appeals filed by the assessee for both the years under consideration stands allowed

ITA 373/BANG/2023[2013-14]Status: DisposedITAT Bangalore28 Aug 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Joseph Varghese
Section 11

…ed by authorities below. We have perused the submissions advanced by both sides in the light of records placed before us. 9.5 The Ld.AR had relied on the decision of Hon'ble Karnataka High Court in case of CIT(E) vs. Ohio University Christ College reported in 408 ITR 352 wherein Hon’ble Court considered the question as to whether, for the purposes of allowing exemption u/s. 11(1)(a) of the act, the income has to be “applied” or “spent”. The Hon’ble Court took the view that the word, “applied” as a wider connotation. In that case, the Hon'ble High Court held that provision for expenditure made in a particular year…

AGASTYA INTERNATIONAL FOUNDATION,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, EXEMPTIONS, CIRCLE-1, , BENGALURU

In the result, appeal filed by the assessee is allowed

ITA 289/BANG/2023[2016-17]Status: DisposedITAT Bangalore31 May 2023AY 2016-17

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2016-17 M/S. Agastya International Foundation, The Assistant Commissioner Of #101, 1St Floor, Varsav Plaza, Income Tax (Exemptions), 12 Jayamahal Main Road, Vs. Circle - 1, Bengaluru – 560 046. Bengaluru. Pan : Aaata 3882 C Appellant Respondent Assessee By : Smt. Suman Lunkar, Ca Revenue By : Shri. Gudimella Vp Pavan Kumar, Jcit (Dr)(Itat), Bengaluru. Date Of Hearing : 31.05.2023 Date Of Pronouncement : 31.05.2023

For Appellant: Smt. Suman Lunkar, CAFor Respondent: Shri. Gudimella VP Pavan Kumar, JCIT (DR)(ITAT), Bengaluru
Section 11Section 12ASection 143(2)Section 143(3)Section 250Section 271(1)(c)

…who were stationed abroad and the utilization of the donation was also for the objects of the Trust. 8. In this context, we rely on the following judicial pronouncements : i) In Ohio University Christ College v. Commissioner of Income Tax reported in [2018] 408 ITR 352 (Karnataka), the Hon’ble court held as under :- "It is also not disputed that the services had been rendered by the faculty members from Ohio University as the classes were taken in Bangalore. The services had been utilized for the purposes of the trust's objectives in India, viz., of imparting higher education in India. Ohio University has also…

LITTLE ANGELS MODERN SCHOOL vs. THE COMMISSIONER OF

In the result, I pass the following:

WP/21676/2021HC Karnataka01 Sept 2022

Bench: The Hon'Ble Mr.Justice S.R. Krishna Kumar

Section 154Section 264

…has relied on the following decisions: (1) 303 CTR (SC) 1: Commissioner of Income Tax (Exemption) vs. Subros Educational Society. (2) (2022) 286 Taxman 97 (SC): Commissioner of Income Tax (Exemption) vs. Subros Educational Society. (3) (2018) 408 ITR 352 (Kar): Commissioner of Income Tax (Exemptions) & Anr. Vs. OHIO University Christ College, Academy for Management Education. (4) (2018) 408 ITR 231 (Kar): Commissioner of Income Tax and another vs. Agricultural Produce Market Committee. (5) 185 CTR 492 (Bom): Commissioner of Income Tax vs. Institute of Banking Personnel. 7…

M/S GOKULA EDUCATION FOUNDATION ,BANGALORE vs. ADDITIONAL DIRECTOR OF INCOME TAX RANGE-17, BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 945/BANG/2017[2011-12]Status: DisposedITAT Bangalore18 Aug 2022AY 2011-12

Bench: Shri George George K. & Shri Padmavathy Sassessment Year: 2011-12

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri Dev Ratan Kumar, CIT(DR)(ITAT), Bengaluru
Section 11(1)(a)Section 11(2)Section 12ASection 139(1)Section 142(1)Section 143(1)Section 143(3)

…d by the order of the CIT(A), assessee has raised ground No.7 before the Tribunal. The learned Counsel for the assessee placed reliance on the decision of the Hon’ble Karnataka Page 24 of 30 High Court in the case of CIT(E) Vs. Ohio University Christ College 408 ITR 352 (Karnataka). In the aforesaid decision, the question that arose for consideration was whether for the purpose of allowing exemption under section 11(1)(a) of the Act, the income has to be ‘applied’ or ‘spent’. The Hon’ble High Court took the view that the word ‘applied’ has a wider connotation. In that case, the Hon’ble High Court held that provi…

M/S GOKULA EDUCATION FOUNDATION MEDICAL ,BANGALORE vs. ADDITIONAL DIRECTOR OF INCOME TAX RANGE-17 , BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 946/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 Jul 2022AY 2011-12

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy Sassessment Year : 2011-12

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri T. Roumuan Paite, CIT(DR)(ITAT), Bengaluru
Section 11Section 11(1)(a)Section 11(2)Section 12ASection 139(1)Section 143(2)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESEIDENT AND SHRI PADMAVATHY S, ACCOUNTANT MEMBER Assessment year : 2011-12 M/s. Gokula Education Foundation – Medical, Vs. The Additional Director MSRIT Post, MSR Nagar, of Income Tax, Bangalore – 560 054. Range 17, PAN: AAATG 1779Q Bangalore. ASSESSEE RESPONDENT Assessee by : Shri Narendra Sharma, Advocate Respondent by : Shri T. Roumuan Paite, CIT(DR)(ITAT), Bengaluru. Date of hearing : 28.06.2022 Date of Pronouncement : 25.07.2022 O R D E R Per Padmavathy S., Accountant Member This appeal by the assessee is dire…

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1, BENGALURU vs. KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD, BENGALURU

In the result, both the appeals filed by revenue are dismissed

ITA 578/BANG/2021[2010-11]Status: DisposedITAT Bangalore05 Jan 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri
Section 11Section 11(1)(a)Section 143(3)Section 2(15)

…lied upon number of judicial pronouncements of this Tribunal. The assessee before the Ld.CIT(A) contended that the issue is squarely covered in its favour by the decision of the Hon’ble Karnataka High Court in the case of Ohio University Christ College (2018) 408 ITR 352, decision of Coordinate Bench of this Tribunal in case of ITO vs. Namma Sangha (2018) 98 taxmann.com 307 and decision of Hon’ble Karnataka High Court in case of Manipal Academy of High Education (2019) 111 taxmann.com 243. It is submitted that the Ld.CIT(A) granted carry forward of excess application to the subsequent year for set off. Aggrieved…

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE-1, BENGALURU vs. KARNATAKA INDUSTRIAL AREAS DEVELOPMENT BOARD, BENGALURU

In the result, both the appeals filed by revenue are dismissed

ITA 577/BANG/2021[2009-10]Status: DisposedITAT Bangalore05 Jan 2022AY 2009-10

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri
Section 11Section 11(1)(a)Section 143(3)Section 2(15)

…lied upon number of judicial pronouncements of this Tribunal. The assessee before the Ld.CIT(A) contended that the issue is squarely covered in its favour by the decision of the Hon’ble Karnataka High Court in the case of Ohio University Christ College (2018) 408 ITR 352, decision of Coordinate Bench of this Tribunal in case of ITO vs. Namma Sangha (2018) 98 taxmann.com 307 and decision of Hon’ble Karnataka High Court in case of Manipal Academy of High Education (2019) 111 taxmann.com 243. It is submitted that the Ld.CIT(A) granted carry forward of excess application to the subsequent year for set off. Aggrieved…

THE PR COMMISSIONER OF INCOME TAX vs. M/S NAVODAYA GRAMA VIKAS CHARITABLE TRUST

The appeal stands disposed of, accordingly

ITA/308/2019HC Karnataka21 Dec 2021

Bench: S.SUJATHA,S VISHWAJITH SHETTY

Section 260A

…al Commissioner of Income-tax (Exemptions) -vs- Manipal Academy of Higher Education2. 3. Learned counsel for the revenue does not dispute the same. 4. We have perused the judgments referred to by the learned counsel for the respondent. 1 (2018) 408 ITR 352 (Karnataka) 2 (2019) 111 taxmann.com 243 (Karnataka) 4 5. In view of the aforesaid submissions and on perusal of the citations referred to by the learned counsel for the respondent as aforesaid, we are of the considered view that no substantial question of law arises for our consideration as we concur with the decisions rendered by the…

INCOME TAX OFFICER (EXEMPTIONS), WARD-2, BANGALORE vs. M/S. MEERABO GLOBAL FOUNDATION , BANGALORE

In the result, the appeal filed by the Revenue is dismissed

ITA 721/BANG/2020[2016-17]Status: DisposedITAT Bangalore21 Oct 2021AY 2016-17

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.Pradeep Kumar, CIT-DRFor Respondent: Sri.Satish Mody, Advocate
Section 10(34)Section 11Section 11(1)(a)Section 11(1)(d)Section 12ASection 143(3)

…he Hon’ble jurisdictional High Court in the case of Pr.CIT (Exemption) v. Agastya International Foundation (supra) by following the earlier judgment of the Hon’ble High Court in the case of CIT (Exemption) v. Ohio Unikversity Christ College reported in (2018) 408 ITR 352 (Kar.), had held as under:- “Income derived from trust property has to be computed on commercial principles and if commercial principles are applied, then adjustment of expenses incurred by the trust for charitable and religious purposes in the earlier years against the income earned by the trust in the subsequent year will have to be regarded a…

THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE- 1, BANGALORE vs. M/S. CHILDRENS EDUCATION SOCIETY, BANGALORE

In the result, all the three appeals of the revenue are dismissed

ITA 699/BANG/2020[2017-18]Status: DisposedITAT Bangalore01 Sept 2021AY 2017-18

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Muzaffar Hussain, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 11(1)(a)Section 12A

…h regard to carrying forward of the losses for being set off against the income of the charitable trust for the present Assessment Year, the controversy is covered by the judgment in CIT (Exemptions) v. Ohio University Christ College [2018] 99 taxmann.com 377/408 ITR 352 (Kar.) in which this Court held as under: "16. In so far as the second question proposed by the Revenue, quoted above is concerned also, we find that the Tribunal's findings in this regard do not give rise to any substantial question of law. The said findings are quoted below for ready reference: "5.1 In the course of assessment proceedings, the…

THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE- 1, BANGALORE vs. M/S. CHILDRENS EDUCATION SOCIETY, BANGALORE

In the result, all the three appeals of the revenue are dismissed

ITA 698/BANG/2020[2016-17]Status: DisposedITAT Bangalore01 Sept 2021AY 2016-17

Bench: Shri B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri Muzaffar Hussain, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 11(1)(a)Section 12A

…h regard to carrying forward of the losses for being set off against the income of the charitable trust for the present Assessment Year, the controversy is covered by the judgment in CIT (Exemptions) v. Ohio University Christ College [2018] 99 taxmann.com 377/408 ITR 352 (Kar.) in which this Court held as under: "16. In so far as the second question proposed by the Revenue, quoted above is concerned also, we find that the Tribunal's findings in this regard do not give rise to any substantial question of law. The said findings are quoted below for ready reference: "5.1 In the course of assessment proceedings, the…

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