CIT v. Ahmedabad Rana Caste Association

140 ITR 1Supreme Court of India1983#1387 most cited

What is CIT v. Ahmedabad Rana Caste Association authority for?

An object beneficial to a section of the public, as distinguished from an individual or group of individuals, qualifies as an object of general public utility under Section 2(15) and hence a charitable purpose. This applies even if the benefits are restricted to a specific caste, community, or professional group.

82

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2007 to 2025.

Also referred to as

CIT v. Ahmedabad Rana Caste Association · 140 ITR 1 · Section 2(15) · general public utility · charitable purpose · section of public · benefit to community · trust registration · Section 11 exemption · Section 12AB · Section 13(1)(b)

Sections most often in play

Section 2(15)Section 11Section 12ASection 12ABSection 10(23EC)Section 13(3)Section 13(8)Section 13(1)(b)

Issues it is cited on

section 4(3)section 10(23c)(iv)section 205application of income for charitable purposessection 36(1)(v)advancement of general public utilitysection 73section 164(2)section 11(6)proviso to section 2(15)section 52section 164

Judgments citing CIT v. Ahmedabad Rana Caste Association

Confederation of Indian Textile Industry, Mumbai vs. ITO (E) 1(2), Mumbai

In the result, we hereby set-aside the order of CIT(A) and the Assessing

ITA 2435/MUM/2019[2013-14]Status: DisposedITAT Mumbai17 Jul 2020AY 2013-14

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm M/S. Confederation Of Indian Vs. Ito(E)(1)(2), Mumbai Textile Industry 1508, Maker Chamber V-221 Nariman Point Mumbai – 400 021 Pan/Gir No.Aaact0174H (Appellant) .. (Respondent)

Section 11Section 12ASection 143(3)Section 25

…e problem. The advancement of an object of benefit to the public or a section of the public is distinguished from an individual or a group of individual would be of charitable purposes. This view was taken in the case of CIT vs Ahmedabad Rana Cast Association 140 ITR 1 (SC). The expression “object of general public utility” in sec. 2(15) prima facie includes all objects which permits the welfare of the general public. It cannot be said that a purpose would cease to be charitable if it includes taking of steps for the promotion of trade, commerce or manufacture. An object beneficial to a section of the public is a…

Income Tax Officer (Exemption), Ward-1, Jaipur vs. M/S Rajasthan Cricekt Association, Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the ground of appeal so taken by the assessee society is thus allowed

ITA 1356/JPR/2018[2011-12]Status: DisposedITAT Jaipur09 Dec 2019AY 2011-12
For Appellant: Shri Shyam Lal Agarwal (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT) &

…re, advancement of any object of benefit to the public or a section of the public or a section of the public as distinguished from benefit to an individual or agroup of individuals would be a charitable purpose ( CIT v. Ahmedabad Rana Caste Association [(183) 140 ITR 1 (SC)]. The said expression would prima facie include all objects which promote the welfare of the general public. If cannot be said that a purpose would cease to be charitable purpose. When an object is to promote or protect the interest of a particular trade or industry that object becomes an object of public utility, but not so, if it seeks to pr…

Income Tax Officer (Exemption), Ward-1, Jaipur vs. Rajasthan Cricket Association, Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the ground of appeal so taken by the assessee society is thus allowed

ITA 1355/JPR/2018[2010-11]Status: DisposedITAT Jaipur09 Dec 2019AY 2010-11
For Appellant: Shri Shyam Lal Agarwal (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT) &

…re, advancement of any object of benefit to the public or a section of the public or a section of the public as distinguished from benefit to an individual or agroup of individuals would be a charitable purpose ( CIT v. Ahmedabad Rana Caste Association [(183) 140 ITR 1 (SC)]. The said expression would prima facie include all objects which promote the welfare of the general public. If cannot be said that a purpose would cease to be charitable purpose. When an object is to promote or protect the interest of a particular trade or industry that object becomes an object of public utility, but not so, if it seeks to pr…

All India Rubber Industries Association, Mumbai vs. Asst CIT (E)1(1), Mumbai

Appeals of the assessee are allowed

ITA 247/MUM/2017[2013-14]Status: DisposedITAT Mumbai12 Oct 2018AY 2013-14

Bench: Shri G.S. Pannu & Shri Ravish Sood: A.Y : 2011-12

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri V. Justin
Section 11Section 12ASection 143(3)Section 23Section 4Section 44A

…e problem. The advancement of an object of benefit to the public or a section of the public is distinguished from an individual or a group of individual would be of charitable purposes. This view was taken in the case of CIT vs Ahmedabad Rana Cast Association 140 ITR 1 (SC). The expression “object of general public utility” in sec. 2(15) prima facie includes all objects which permits the welfare of the general public. It cannot be said that a purpose would cease to be charitable if it includes taking of steps for the promotion of trade, commerce or manufacture. An object beneficial to a section of the public is a…

All India Rubber Industries Association, Mumbai vs. ADIT (E) II(2), Mumbai

Appeals of the assessee are allowed

ITA 3994/MUM/2016[2011-12]Status: DisposedITAT Mumbai12 Oct 2018AY 2011-12

Bench: Shri G.S. Pannu & Shri Ravish Sood: A.Y : 2011-12

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri V. Justin
Section 11Section 12ASection 143(3)Section 23Section 4Section 44A

…e problem. The advancement of an object of benefit to the public or a section of the public is distinguished from an individual or a group of individual would be of charitable purposes. This view was taken in the case of CIT vs Ahmedabad Rana Cast Association 140 ITR 1 (SC). The expression “object of general public utility” in sec. 2(15) prima facie includes all objects which permits the welfare of the general public. It cannot be said that a purpose would cease to be charitable if it includes taking of steps for the promotion of trade, commerce or manufacture. An object beneficial to a section of the public is a…

All India Rubber Industries Association, Mumbai vs. ITO (E) 1(1), Mumbai

Appeals of the assessee are allowed

ITA 1368/MUM/2016[2012-13]Status: DisposedITAT Mumbai12 Oct 2018AY 2012-13

Bench: Shri G.S. Pannu & Shri Ravish Sood: A.Y : 2011-12

For Appellant: Ms. Aarti VissanjiFor Respondent: Shri V. Justin
Section 11Section 12ASection 143(3)Section 23Section 4Section 44A

…e problem. The advancement of an object of benefit to the public or a section of the public is distinguished from an individual or a group of individual would be of charitable purposes. This view was taken in the case of CIT vs Ahmedabad Rana Cast Association 140 ITR 1 (SC). The expression “object of general public utility” in sec. 2(15) prima facie includes all objects which permits the welfare of the general public. It cannot be said that a purpose would cease to be charitable if it includes taking of steps for the promotion of trade, commerce or manufacture. An object beneficial to a section of the public is a…

G D Educational Society, Noida vs. JCIT, Range- 1, Noida

In the result, the appeal of the assessee is allowed

ITA 3925/DEL/2017[2013-14]Status: DisposedITAT Delhi30 Jul 2018AY 2013-14

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 11Section 12Section 13Section 234

…ng to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be charit…

G D Educational Society, Noida vs. JCIT, Range- 1, Noida

In the result, the appeal of the assessee is allowed

ITA 3924/DEL/2017[2010-11]Status: DisposedITAT Delhi30 Jul 2018AY 2010-11

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 11Section 12Section 13Section 234

…ng to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be charit…

G D Educational Society, Noida vs. JCIT, Range- 1, Noida

In the result, the appeal of the assessee is allowed

ITA 3923/DEL/2017[2009-10]Status: DisposedITAT Delhi30 Jul 2018AY 2009-10

Bench: Shri R. K. Panda & Ms Suchitra Kamble

Section 11Section 12Section 13Section 234

…ng to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be charit…

Rama Devi Memorial Educational Society, Noida vs. JCIT, Range-2, Noida

In the result, the appeal of the assessee is allowed for

ITA 4434/DEL/2017[2010-11]Status: DisposedITAT Delhi05 Jul 2018AY 2010-11

Bench: Shri H.S. Sidhuassessment Year: 2010-11

For Appellant: Dr. Rakesh Gupta, Adv. &For Respondent: Sh. Ravi Kant Gupta, Sr. DR
Section 10Section 11Section 13Section 143(3)Section 2(15)Section 40

…ng to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be charit…

The Christia Literature Society, Chennai vs. JCIT (OSD), Chennai

In the result, I set aside the orders of the lower authorities

ITA 2818/CHNY/2016[2009-10]Status: DisposedITAT Chennai21 Apr 2017AY 2009-10

Bench: Shri Abraham P. George]

For Appellant: Smt. B. Jaisheila, C.AFor Respondent: Shri. B. Sahadevan, IRS, JCIT
Section 11

…who pay homage and worship at such samadhis and holding of fairs [CIT vs. Guryani Brij Balabh Kaur Trust (: (1980) 125 ITR 381 (P&H)]; promotion of unity and brotherhood :- 19 -: amongst members of a community [CIT vs. Ahmedabad Rana Caste Association (1983) 140 ITR 1 (SC)]. Such activities prompted by religious sentiments have been held to be pursuance of a charitable purpose. But overlapping of charity in a religion will not convert a religious activity to one of ‘’general public utility’’. 20. In the Indian Constitution, the word 'religion' has been used in many places. Terms like 'religion', 'religious…

Dy D.I.T. (E)-I(1), Mumbai vs. The Mumbai Metropolitan Region Development Authority (Mmrda), Mumbai

In the result, both the appeals filed by Revenue and Assessee are dismissed

ITA 4177/MUM/2008[2005-2006]Status: DisposedITAT Mumbai13 Jul 2016AY 2005-2006

Bench: Shri R.C. Sharma & Shri Sanjay Garg

For Appellant: Shri Ronak G. Doshi, A.RFor Respondent: Shri N.P. Singh, D.R
Section 10Section 10(20)Section 11Section 12ASection 13

…c l a s s . T h e r e f o r e , advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public M/s. The Mumbai Metropolitan Region Development Authority (MMRDA) welfare is intended to be served. If the primary purpose and the predominant object are to pr…

M/S. Mumbai Metropolitan Region Development Authority, Mumbai vs. The ADIT(E) RG- 1, Mumbai

In the result, both the appeals filed by Revenue and Assessee are dismissed

ITA 3841/MUM/2008[2005-2006]Status: DisposedITAT Mumbai13 Jul 2016AY 2005-2006

Bench: Shri R.C. Sharma & Shri Sanjay Garg

For Appellant: Shri Ronak G. Doshi, A.RFor Respondent: Shri N.P. Singh, D.R
Section 10Section 10(20)Section 11Section 12ASection 13

…c l a s s . T h e r e f o r e , advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose—CIT v. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public M/s. The Mumbai Metropolitan Region Development Authority (MMRDA) welfare is intended to be served. If the primary purpose and the predominant object are to pr…

Principal Commissioner of Income Tax-2 vs. M/s Indur Green Power Private Limited

ITTA/627/2015HC Telangana02 Jun 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

M/S. Greater Noida Industrial Development Authority, Uttar Pradesh vs. CIT (E), Lucknow

The appeal is allowed

ITA 113/DEL/2016[]Status: DisposedITAT Delhi19 May 2016

Bench: Shri I.C. Sudhir & Shri L.P. Sahu Assessment Year: -- Greater Noida Industrial Development Vs. Cit(E), Authority, H-169, Chitvan Estate, Lucknow. Sector-Gamma, Gr. Noida City, District – Gautam Budh Nagar. Uttar Pradesh. (Pan: Aaalg0129L) (Appellant) (Respondent) Assessment Year: - - Yamuna Expressway Industrial Development Vs. Cit(E), Authority, First Floor, Commercial Complex, Lucknow. P-2, Sector-Omega 1, Greater Noida Gautam Budh Nagar, Uttar Pradesh. (Pan: Aaalt0341D) Assessee By: S/Shri Balbir Singh & Abhinav Mehrotra, Adv., Sk Gupta & Ms. Raj Rani, Cas. Department By: Shri Sandeep Kumar, Cit( Dr) Date Of Hearing : 02 .03.2016 Date Of Pronouncement: 18 :05.2016 Order Per I.C. Sudhir:

For Appellant: S/Shri Balbir Singh & AbhinavFor Respondent: Shri Sandeep Kumar, CIT( DR)
Section 12ASection 2(15)Section 3Section 6

…to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose [CIT vs. Ahmedabad Rana Caste Association, [1983] 140 ITR 1 (SC)]. The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be chari…

Director of Income Tax vs. M/S Group Vocational

The appeal is dismissed

ITA/199/2015HC Karnataka23 Feb 2016

Bench: S.SUJATHA,JAYANT PATEL

Section 12ASection 12aSection 13Section 2(15)Section 260

…whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose CIT vs. Ahmedabad Rana Caste Association [1983] 140 ITR 1 (SC). The said expression would prima facie include all objects which promote the welfare of the general public. It 7 cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public, the pu…

The Commissioner of Income Tax vs. The Bagalkot Town Development Authority

ITA/100027/2014HC Karnataka15 Dec 2015

Bench: S.ABDUL NAZEER,P.S.DINESH KUMAR

Section 11Section 11(1)(a)Section 11(2)Section 12Section 260ASection 263

…ny object of benefit to the 13 public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose (CIT v. Ahmedabad Rana Caste Assn. [(1982) 2 SCC 542 : 1982 SCC (Tax) 151 : (1983) 140 ITR 1]). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be charitabl…

M/S Rabiya Basari Brahamath-Ullah Allayha Charitable Trust vs. CIT

In the result, the assessee's appeals are allowed

ITA 423/BANG/2013[2008-09]Status: DisposedITAT Bangalore06 Nov 2015AY 2008-09

Bench: Smt. Asha Vijayaraghavan & Shri Jason P. Boaz

For Appellant: Shri S. Venkatesan, CAFor Respondent: Kum. Neera Malhotra, CIT
Section 1Section 12ASection 13Section 13(1)(b)Section 2(15)

…n appeal before the Tribunal raising several grounds. The co- ordinate bench of this Tribunal after hearing of the assessee's appeal including its reliance on the decision of the Hon'ble Apex Court in the case of Ahmedabad Rana Caste Association reported in 140 ITR 1 set aside the order of the ld. CIT and remanded the issue of grant of registration for fresh consideration vide its order in ITA No.1237/Bang/2011 dt.12.9.2012 granting the assessee liberty to put forth all its contentions in this regard. 2.3 Subsequent to the order of the ITAT, Bangalore in ITA No.1237/Bang/2011 dt.12.9.2012, the assessee app…

Sadiya Educational and Charitable Trust vs. CIT

In the result, the assessee's appeals are allowed

ITA 422/BANG/2013[2008-09]Status: DisposedITAT Bangalore04 Sept 2015AY 2008-09

Bench: Smt. P. Madhavi Devi & Shri Jason P. Boazi.T. A. Nos.422 & 1632/Bang/2013 M/S. Sadiya Educational & Charitable Trust, Mattadgadde Road, Sadiya Nagar, Shiralkoppa-577 428 …. Appellant.

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri G.R. Reddy, CIT (D.R)
Section 12ASection 13(1)(b)Section 2(15)

…d an appeal before the Tribunal raising several grounds. The co-ordinate bench of this Tribunal after hearing of the assessee's appeal including its reliance on the decision of the Hon'ble Apex Court in the case of Ahmedabad Rana Caste Association reported in 140 ITR 1 set aside the order of the ld. CIT and remanded the issue of grant of registration for fresh consideration vide its order in ITA No.1235/Bang/2011 dt.12.9.2012 granting the assessee liberty to put forth all its contentions in this regard. 2.3 Subsequent to the order of the ITAT, Bangalore in ITA No.1235/Bang/2011 dt.12.9.2012, the assessee appeared…

Commissioner of Income Tax vs. Agricultural Market Committee

ITTA/251/2008HC Telangana01 Mar 2011

Bench: V.V.S.RAO,RAMESH RANGANATHAN

For Respondent: Ms. K.Lalitha, Standing Counsel for
Section 10(20)Section 10(29)Section 12ASection 260ASection 4Section 4(1)

…rtaining to a whole class. Therefore, advancement of any object of benefit to the public or a section of the public as distinguished from benefit to an individual or a group of individuals would be a charitable purpose (CIT v. Ahmedabad Rana Caste Assn (1983) 140 ITR 1 (SC)). The said expression would prima facie include all objects which promote the welfare of the general public. It cannot be said that a purpose would cease to be charitable even if public welfare is intended to be served. If the primary purpose and the predominant object are to promote the welfare of the general public the purpose would be chari…