CIT v. Dawoodi Bohra Jamat

364 ITR 31Supreme Court of India2014#1378 most cited

What is CIT v. Dawoodi Bohra Jamat authority for?

A trust's objects, even if based on religious tenets, can qualify as charitable for tax exemptions if its benefits are not exclusively restricted to a particular religious community or caste.

83

judgments rely on this decision, according to BharatTax’s citation analysis of 371,886 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Dawoodi Bohra Jamat · Section 13(1)(b) · Section 11 · Section 12A · Section 2(15) · charitable trust · religious trust · general public utility · benefit not restricted to particular community · trust registration · income tax exemption · objects of trust

Also reported as

222 Taxmann 228

Sections most often in play

Section 12ASection 12ABSection 11Section 13(1)(b)Section 80GSection 2(15)Section 80G(5)Section 12A(1)(ac)(iii)

Issues it is cited on

section 13(1)(b)section 80g(5b)section 13(1)section 115bbccorpus fundsection 80g(2)anonymous donationsection 11(1)(d)section 12ab(4)section 12ab(1)(b)(ii)section 11(5)section 11(1)(a)

Judgments citing CIT v. Dawoodi Bohra Jamat

Kizhakke Kovilakom Trust, Malappuram vs. The CIT (Exemption), Kochi

In the result, the appeal of the assessee is allowed

ITA 474/COCH/2023[2023-24]Status: DisposedITAT Cochin02 Dec 2024AY 2023-24

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2023-24

For Appellant: Shri Suresh Kumar Varma, CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 12ASection 80G(5)(vi)

…CIT, the Pune bench of the Tribunal had given the following findings and held that there is no bar under the statute that religious trust cannot be granted registration u/s 12A of the Act. “11. The Hon'ble Supreme Court in CIT Vs. Dawoodi Bohra Jamat, (2014) 364 ITR 31 (SC) had observed that the objects of trust as declared in the Trust Deed would govern its right of exemption under sections 11 and 12 of the Act. The Hon'ble Supreme Court also recognized the creation or establishment of trust for either religious or charitable or both religious and charitable purposes. By looking at the objects of the trust, it…

Shri Samasta Kutchi Dasa Oswal Jain Mahajan, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

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

ITA 4894/MUM/2024[2025-26]Status: DisposedITAT Mumbai13 Nov 2024AY 2025-26

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI OMKARESHWAR CHIDARA (Accountant Member)

Section 12ASection 12A(1)(ac)Section 13(1)(b)Section 80GSection 80G(5)

…ide the issue afresh and pass speaking order after considering all the relevant materials filed before us and also various judgments including the principles laid down by the Hon’ble Supreme Court in the case of CIT vs. Dawoodi Bohra Jamaat reported in (2014) 364 ITR 31 (SC). 6. In the result, appeal of the assessee is allowed for statistical purposes. Order pronounced on 13th November, 2024. (OMKARESHWAR CHIDARA) JUDICIAL MEMBER Mumbai; Dated 13/11/2024 KARUNA, sr.ps 4 Shri Samasta Kutchi Dasa Oswal Jain Mahajan Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5.…

Aryagram Virasat Foundation, Ahmedabad vs. The CIT(Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1103/AHD/2024[NA]Status: DisposedITAT Ahmedabad25 Oct 2024

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: Na Aryagram Virasat Foundation, Vs. Commissioner Of Income- P No. 300/23, Kanya Gurukul, Tax (Exemption), Nr. Sent Ann School, Nr. Hira Ahmedabad Jain Society, Ramnagar, Sabarmati, Ahmedabad-380005 Pan : Aaqca 9818 H अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Devan Kapadia, Ar Revenue By : Shri V. Nandakumar, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 21.10.2024 घोषणा की तारीख /Date Of Pronouncement: 25.10.2024

For Appellant: Shri Devan Kapadia, ARFor Respondent: Shri V. Nandakumar, CIT-DR
Section 80GSection 80G(5)Section 80G(5)(iii)

…n followed by its trustees. 13. As for the reference to setting up Upashrays, which is a place of resting for Jain Monks, that, we hold, does not make the character of the trust religious. The Hon’ble apex court in the case of CIT vs Dawoodi Bohra Jamat (SC) 364 ITR 31 interpreted the phrase religious purpose , in relation to trusts, to mean purposes relating to religion, devoted to religion, exhibiting spiritual or practical effects of religion, following the requirements of religion; pious, godly, devout. Religious purposes it held indicated those which included the advancement, support or propagation of relig…

St. George Trust, Chennai vs. CIT (Exemptions), Chennai

In the result, appeal of the assessee is allowed

ITA 1795/CHNY/2024[-]Status: DisposedITAT Chennai01 Oct 2024

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)

For Appellant: Shri Muthu Abirami, AdvocateFor Respondent: Shri R. Clement Ramesh Kumar
Section 12ASection 80GSection 80G(5)Section 80G(5)(iii)Section 80G(5)(iv)

…ed 04/05/2022. 6. Further, the Ld.AR stated that religious activities would come under charity, so long as the religious activities are not discriminatory in nature, by relying on the decision of the Hon’ble Supreme court in CIT Vs.Dawoodi Bohara Jamat [2014] 364 ITR 31 (SC). :- 8 -: 7. The Ld.AR further argued that the application of the assessee is rejected, even though the assessee has explained in their reply that while filing Form 10AB, in column 3 the nature of activity was wrongly mentioned as “Religious and Charitable” and in column 5 objects of the applicants as “Religious” and hence relied on the follow…

Vardhman Sathanakvasi Jain Sravak Sangh, Ajmer vs. CIT(E), Jaipur

ITA 696/JPR/2024[NA]Status: DisposedITAT Jaipur27 Sept 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)
Section 12ASection 12A(1)(ab)Section 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

…act that there are other objects which fall under the category of charitable purpose which cannot be construed as solely of the benefit of particular religious community and following the judgment of Hon’ble Supreme court in case of CIT vs. Dawoodi Bohra Jamat364 ITR 31 directed the CIT to grant registration to the assessee trust. 3. As per section 12AB of the Act, the CIT on receipt of the application made by the assessee u/s 12A(1)(ac) of the Act shall call for such document or information or make such enquiries as he thinks necessary to satisfy about the genuineness of the activities and the compliance of such…

Vardhman Sathanakvasi Jain Sravak Sangh, Ajmer vs. CIT(E), Jaipur

ITA 695/JPR/2024[NA]Status: DisposedITAT Jaipur27 Sept 2024

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Ajey Malik (CIT)
Section 12ASection 12A(1)(ab)Section 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

…act that there are other objects which fall under the category of charitable purpose which cannot be construed as solely of the benefit of particular religious community and following the judgment of Hon’ble Supreme court in case of CIT vs. Dawoodi Bohra Jamat364 ITR 31 directed the CIT to grant registration to the assessee trust. 3. As per section 12AB of the Act, the CIT on receipt of the application made by the assessee u/s 12A(1)(ac) of the Act shall call for such document or information or make such enquiries as he thinks necessary to satisfy about the genuineness of the activities and the compliance of such…

Renewed Hope Community Trust, New Panvel vs. Commissioner of Income Tax Exemptions Pune, Pune

In the result, Appeal of the assessee is allowed for statistical purposes

ITA 4542/MUM/2023[NOT APPLICABLE]Status: DisposedITAT Mumbai22 Jul 2024

Bench: Shri Prashant Maharishi, Am & Shri Sunil Kumar Singh, Jm Renewed Hope Community Commissioner Of Income Trust Tax Exemption Pune 322, 3Rd Floor, Income Tax 42, Vighnaharta Enclave, Matheran Road, Office Vs. New Panvel, Pmt Building, Swargate, Navi Mumbai, Thane- Shankar Sheth Road, 410206 Pune-411037 (Appellant) (Respondent) Pan No. Aaetr5822

For Appellant: Mr. Rohan N. Dedhia, ARFor Respondent: Mr. Rajesh Meshram, DR
Section 12A

…held that provisions of Section 13 can be invoked by Assessing Officer while framing assessment and not by Commissioner while considering application for registration under Section 12AA. In the case of Dawoodi Bohara Jamat [2014] 43 taxmann.com 243/268 CTR 1/364 ITR 31/222 Taxman 228 (SC), the Hon'ble Supreme Court made the following observations: "40. Further, establishment of Madarsa or institutions to impart religious education to the masses would qualify as a charitable purpose qualifying under the head of education under the provisions of Section Renewed Hope Community Trust; A.Y. 2022-23 2(15) of the Act.…

National Real Estate Development Council Gujarat, Ahmedabad vs. The Commissioner of Income Tax (Exemption), Ahmedabad

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

ITA 487/AHD/2024[NA]Status: DisposedITAT Ahmedabad02 Jul 2024

Bench: Shri Siddhartha Nautiyal & Shri Makarand Vasant Mahadeokarassessment Year : - National Real Estate Development Vs. Commissioner Of Council Gujarat Income-Tax (Exemption) B-807, Times Square-2 Ahmedabad. Nr.Avlon Hotel, Thaltej Ahmedabad. Pan : Aagan 1280 J

Section 12ASection 13(3)

…held that provisions of Section 13 can be invoked by Assessing Officer while framing assessment and not by Commissioner while considering application for registration under Section 12AA. In the case of Dawoodi Bohara Jamat [2014] 43 taxmann.com 243/268 CTR 1/364 ITR 31/222 Taxman 228 (SC), the Hon'ble Supreme Court made the following observations: "40. Further, establishment of Madarsa or institutions to impart religious education to the masses would qualify as a charitable purpose qualifying under the head of education under the provisions of Section 2(15) of the Act. The institutions established to spread rel…

Om Kothari Foundation, Jaipur, Rajasthan vs. ITO, (Exemption) Ward-1, Jaipur, Rajasthan

In the result, the appeals of the assessee in ITA No

ITA 57/JPR/2024[2009-10]Status: DisposedITAT Jaipur04 Jun 2024AY 2009-10

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Anish Maheshwari, CAFor Respondent: Shri A.S. Nehra, Addl.CIT
Section 10Section 11Section 12ASection 13(1)Section 13(1)(d)Section 143(3)Section 147Section 164(2)

…of the organization will not lose exemption and only the income from such prohibited investments will be subject to tax. Reliance is place on decision:- a. Hon’ble Supreme Court in the case of COMMISSIONER OF INCOME TAX VERSUS M/S. DAWOODI BOHARA JAMAT [2014] 364 ITR 31 (SC) Claim of benefit of exemption u/s 11 and 12 r.w.s. 13 of the Act – Public religious trust – Whether the Courts were justified in coming to the conclusion that the respondent- trust is a public religious trust and is outside the purview of Section 13(1)(b) and eligible for 24 OM KOTHARI FOUNDATION VS ITO (EXEMPTION), WARD -1 , JAIPUR exemption…

Mandir Shree Bhairav Ji Trust, Jaipur vs. CIT Exemption, Jaipur

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

ITA 427/JPR/2023[NA]Status: DisposedITAT Jaipur02 Nov 2023

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Vikash Rajvanshi (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 12ASection 80GSection 80G(5)

…for 80G Registration and not claiming any 80G Deduction . So above mentioned case law is not applicable. 9 Mandir Shree Bhairav Ji Trust vs. CIT Exemption Whereas, we emphasis decision of Hon’ble Supreme Court in the case of CIT v.Dawoodi Bohra Jamat (2014) 364 ITR 31 (SC) in support of our claim that the Assessee is entitled to registration as a “Charitable Institution”. The facts of the case before the Hon’ble Supreme Court, was a case in which some of the objects of the institution were religious and some charitable. The objects of the trust exhibited dual tenor of religious and charitable purposes and activ…

Dy. Commissioner O Income Tax (Exemption)-2(1), Mumbai vs. Shree Sai Baba Sansthan Trust(Shirdi), Mumbai

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

ITA 3210/MUM/2022[2017-18]Status: DisposedITAT Mumbai25 Oct 2023AY 2017-18
For Appellant: Shri S. Ganesh – Sr. CounselFor Respondent: Dr Kishor Dhule (CIT-DR)
Section 10Section 115BSection 12ASection 143(2)Section 80G

…having regard to the objects and activities of the assessee, there was no doubt it was existing both for charitable and religious purposes. The Ld.Sr.Counsel also relied on the decisions of the Hon’ble Supreme Court in the case of CIT Vs Dawoodi Bohra Jamat (364 ITR 31) and Hon’ble Delhi High Court in the case of CIT Vs Bhagwan Shree LaxmiNaraindham Trust (378 ITR 222). In both these cases, according to him, it was held that ‘religious purpose’ under the Act has a wider meaning and even the spreading of spirituality is a religious purpose. 16. The Ld.Sr.Counsel further submitted that Section 80G operates in a co…

Dy. Commissioner O Income Tax (Exemption)-2(1), Mumbai vs. Shree Sai Baba Sansthan Trust(Shirdi), Mumbai

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

ITA 3209/MUM/2022[2018-19]Status: DisposedITAT Mumbai25 Oct 2023AY 2018-19
For Appellant: Shri S. Ganesh – Sr. CounselFor Respondent: Dr Kishor Dhule (CIT-DR)
Section 10Section 115BSection 12ASection 143(2)Section 80G

…having regard to the objects and activities of the assessee, there was no doubt it was existing both for charitable and religious purposes. The Ld.Sr.Counsel also relied on the decisions of the Hon’ble Supreme Court in the case of CIT Vs Dawoodi Bohra Jamat (364 ITR 31) and Hon’ble Delhi High Court in the case of CIT Vs Bhagwan Shree LaxmiNaraindham Trust (378 ITR 222). In both these cases, according to him, it was held that ‘religious purpose’ under the Act has a wider meaning and even the spreading of spirituality is a religious purpose. 16. The Ld.Sr.Counsel further submitted that Section 80G operates in a co…

Dy. Commissioner of Income Tax (Exemption) 2(1), Mumbai vs. Shree Sai Baba Sansthan Trust (Shirdi), Mumbai

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

ITA 3049/MUM/2022[2015-16]Status: DisposedITAT Mumbai25 Oct 2023AY 2015-16
For Appellant: Shri S. Ganesh – Sr. CounselFor Respondent: Dr Kishor Dhule (CIT-DR)
Section 10Section 115BSection 12ASection 143(2)Section 80G

…having regard to the objects and activities of the assessee, there was no doubt it was existing both for charitable and religious purposes. The Ld.Sr.Counsel also relied on the decisions of the Hon’ble Supreme Court in the case of CIT Vs Dawoodi Bohra Jamat (364 ITR 31) and Hon’ble Delhi High Court in the case of CIT Vs Bhagwan Shree LaxmiNaraindham Trust (378 ITR 222). In both these cases, according to him, it was held that ‘religious purpose’ under the Act has a wider meaning and even the spreading of spirituality is a religious purpose. 16. The Ld.Sr.Counsel further submitted that Section 80G operates in a co…

Shree Sai Baba Sansthan Trust (Shirdi), Mumbai vs. Dy. Commissioner of Income Tax (Exemption) 2(1), Mumbai

In the result, appeal of assessee is partly allowed and appeals of the revenue are dismissed

ITA 3010/MUM/2022[2015-2016]Status: DisposedITAT Mumbai25 Oct 2023AY 2015-2016
For Appellant: Shri S. Ganesh – Sr. CounselFor Respondent: Dr Kishor Dhule (CIT-DR)
Section 10Section 115BSection 12ASection 143(2)Section 80G

…having regard to the objects and activities of the assessee, there was no doubt it was existing both for charitable and religious purposes. The Ld.Sr.Counsel also relied on the decisions of the Hon’ble Supreme Court in the case of CIT Vs Dawoodi Bohra Jamat (364 ITR 31) and Hon’ble Delhi High Court in the case of CIT Vs Bhagwan Shree LaxmiNaraindham Trust (378 ITR 222). In both these cases, according to him, it was held that ‘religious purpose’ under the Act has a wider meaning and even the spreading of spirituality is a religious purpose. 16. The Ld.Sr.Counsel further submitted that Section 80G operates in a co…

Math Garwa Ghat (Trust), Varanasi vs. Commissioner of Income Tax (Exemptions), Lucknow

In the result, the appeal of the assessee is allowed

ITA 33/VNS/2023[NA]Status: DisposedITAT Varanasi29 Sept 2023

Bench: Shri. B. R. Baskaran & Shri Amit Shuklaassessment Year: N.A. Math Gadwaghat Trust V. The Cit (Exemptions) Bangla Kuti, Ramna Varanasi Varanasi Tan/Pan:Aaets8008G (Appellant) (Respondent)

For Appellant: Shri Ashish Jindal & Shri V. K. JindalFor Respondent: Shri Robin Chaudhary, CIT
Section 11Section 12ASection 143(3)

…mptions) is set aside. Accordingly, we direct the ld. CIT (Exemptions) to grant registration to the assessee-trust under section 12AB of the Act. 10. The ld. CIT has cited the judgment of the Hon'ble Supreme Court in the case of CIT vs. Dawoodi Bohara Jamat, 364 ITR 31 (SC). We are unable to understand as to why the ld. :-12-: CIT has referred to this judgment, as this is judgment is squarely in favour of the assessee, wherein the Hon'ble Apex Court has held that if the assessee-trust is formed with both religious and charitable objects, the claim for registration under section 12AA of the Act cannot be denied…

Infoparks Kerala, Cochin vs. The ACIT, Cochin

In the result, the assessee’s appeals are partly allowed

ITA 77/COCH/2015[2011-12]Status: DisposedITAT Cochin11 Aug 2023AY 2011-12

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

…’ (IFHP), and cannot be treated as business income. Reliance stood also placed by it on the decisions in Addl.CIT v. Surat Art and Silk Mfrs. Assn. [1980] 121 ITR 1 (SC); CIT v. Gujarat Maritime Board [2007] 295 ITR 561 (SC); CIT v. Dawoodi Bohra Jamat [2014] 364 ITR 31 (SC); and DIT(E) v. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Guj). 4.3 Before us, it was a common contention of the parties that the issue is squarely covered by the recent decision by the Hon’ble Apex Court in Asst. CIT v. Ahmedabad Urban Development Authority [2022] 449 ITR 1(SC), placing a copy thereof on record. No assistance, howe…

Infoparks Kerala, Trivandrum vs. The Jt Director of It (OSD) Exem), Cochin

In the result, the assessee’s appeals are partly allowed

ITA 76/COCH/2015[2010-11]Status: DisposedITAT Cochin11 Aug 2023AY 2010-11

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

…’ (IFHP), and cannot be treated as business income. Reliance stood also placed by it on the decisions in Addl.CIT v. Surat Art and Silk Mfrs. Assn. [1980] 121 ITR 1 (SC); CIT v. Gujarat Maritime Board [2007] 295 ITR 561 (SC); CIT v. Dawoodi Bohra Jamat [2014] 364 ITR 31 (SC); and DIT(E) v. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Guj). 4.3 Before us, it was a common contention of the parties that the issue is squarely covered by the recent decision by the Hon’ble Apex Court in Asst. CIT v. Ahmedabad Urban Development Authority [2022] 449 ITR 1(SC), placing a copy thereof on record. No assistance, howe…

Infoparks Kerala, Trivandrum vs. The Jt Director of It (OSD) Exem), Cochin

In the result, the assessee’s appeals are partly allowed

ITA 75/COCH/2015[2009-10]Status: DisposedITAT Cochin11 Aug 2023AY 2009-10

Bench: Shri Sanjay Arora, Am & Shri Aby T. Varkey, Jm

For Appellant: Sri. Rajakannan, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr.AR
Section 11Section 11(1)Section 12ASection 143(3)Section 2(15)

…’ (IFHP), and cannot be treated as business income. Reliance stood also placed by it on the decisions in Addl.CIT v. Surat Art and Silk Mfrs. Assn. [1980] 121 ITR 1 (SC); CIT v. Gujarat Maritime Board [2007] 295 ITR 561 (SC); CIT v. Dawoodi Bohra Jamat [2014] 364 ITR 31 (SC); and DIT(E) v. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Guj). 4.3 Before us, it was a common contention of the parties that the issue is squarely covered by the recent decision by the Hon’ble Apex Court in Asst. CIT v. Ahmedabad Urban Development Authority [2022] 449 ITR 1(SC), placing a copy thereof on record. No assistance, howe…

Madarsa Mazahir Uloom (Waqf), Saharanpur vs. CIT(Exemption), Lucknow

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

ITA 1436/DEL/2018[2017-18]Status: DisposedITAT Delhi22 Feb 2023AY 2017-18

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Ms. Apporva Bhardwaj, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 11Section 12ASection 13Section 2(15)

…e benefit of a particulars religious community or caste. The objects of the trust must be charitable covered within the meaning of section 2(15). It was submitted that the similar issue was settled by the Hon’ble Supreme Court in CIT Vs. Dawoodi Bohara Jamat (364 ITR 31). The Hon’ble Supreme Court held that where assessee trust is formed with both religious and charitable objects, in terms of section 13(1(b), its claim for registration under section 12AA can be denied only in a case when such objects are carried out for benefit of a particular religious community or caste. Hence, the matter is being referred to t…

DCIT, Exemption Circle, Ghaziabad vs. Bharat Sushamachar Samiti, Dehradun

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

ITA 1402/DEL/2020[2016-17]Status: DisposedITAT Delhi23 Nov 2022AY 2016-17
For Appellant: Shri George Koshi, CAFor Respondent: Shri Kanav Bali, Sr. DR
Section 11Section 12ASection 143(3)Section 2Section 2(15)

…seminary is an educational institution. Therefore, it allowed the assessee benefit of exemption 5 ITA No.1401/Del./2020 ITA No.1402/Del./2020 u/s 10 (23C) (iiiad) of the Act. Recently the Hon'ble Supreme Court in the case of CIT vs Dawoodi Bohra Jamat (2014) 364 ITR 361 favoured exemption u/s 11 to be given to the orqanization. The facts of this case were that the assessee's application for registration u/s 12A was rejected by the CIT(A) holding that as the object and purpose of the trust was confined only to a particular religious community, the same would attract the provisions of section 13 (1)(b). In this ca…