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

Asha Deep Foundation, New Delhi vs. ITO (E), Ward- 1(1), New Delhi

In the result, both appeals of the assessee are allowed for statistical

ITA 3349/DEL/2019[2010-11]Status: DisposedITAT Delhi09 Sept 2021AY 2010-11
Section 11Section 13Section 147

…lusively. 4. The ld. AR relying on his submissions submitted that humanitarian efforts have been done the matter may be remanded back for proper consideration in the light of the decision of the Apex Court in the case of CIT Vs Dawood Bohara Jamaat (2014) 364 ITR 31 (S.C.). 5. I have heard the submissions and perused the material available on record. On a consideration thereof I am of the view that the finding arrived at cannot be upheld. The reason for coming to the said conclusion is based on the fact that the ld. CIT(A) has approached the entire issue in a manner which cannot be given judicial recognition…

Shiromani Gurdwara Parbandhak Committee vs. Commissioner of Income Tax-I

In the result the appeal of the Assessee is allowed

ITA 530/ASR/2009[]Status: DisposedITAT Amritsar16 Aug 2021

Bench: : Shri Laliet Kumar & Dr. Mitha Lal Meenav.S. Cit – I Shirmoni Gurdwara Parbandhak Committee Amritsar Teja Singh Mundri Hall Sri Amritsar Pan:Aants1981K (Appellant) (Respondent)

Section 10Section 12ASection 2Section 80Section 80GSection 80G(5)(iii)

…opy of Order in the case of Chief Khalsa Diwan dated 24.04.2009 placed on record along filed Written Submissions in the Hon’ble Court on 29.07.2010. 5. Case Laws: In this regard reliance is placed on the following decisions: a. CIT vs. M/s DawoodiBoharaJamat 364 ITR 31 (SC) b. CIT v. Christian Medical College (2015) 374 ITR 17 (P&H) c. Sri MarudharKesariSthanakwasi Jain Yadgar Samiti Trust V/s Union of India (2005) 273 ITR 475 (Raj.) d. MishrilalGordhanlal Batra charitable trust v/s Union of India (2008) 307 ITR 221(RAJ.). e. Umaid Charitable trust v/s Union of India (2008) 307 ITR 226 (RAJ.) f. Commissioner Of…

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

ITA 5317/DEL/2017[2012-13]Status: DisposedITAT Delhi15 Mar 2021AY 2012-13

Bench: Shri Amit Shukla & Shri Prashant Maharishidcit, M/S. Bharat Sushamachar Samiti, P. O. Kulhan, Vs. Exemption Circle, Sahastradhara Road, Dehradun. Ghaziabad. Pan: Aaabb0034D (Appellant) (Respondent)

For Appellant: Shri George Koshi, C.AFor Respondent: Shri Sat Pal Gulati [CIT] – DR
Section 11Section 12ASection 143(3)Section 2(15)

…g in the seminaries are education and seminary is a educational institutions. Therefore it allowed the assessee benefit of exemption u/s 10(23C)(mad) of the I T.Act Recently the Hon'ble Supreme Court of India in the case of CIT vs. Dawoodi Bohra Jarnat (2014) 364 ITR 361 (SC) favoured exemption u/s 11 to be given to the organization 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 provision of section 13(1)(b). In this…

Brahman Sabha Karveer, Kolhapur vs. Commissioner of Income-Tax Exemption, Pune

In the result, the appeal of the assessee is allowed

ITA 626/PUN/2020[2020-21]Status: DisposedITAT Pune07 Jan 2021AY 2020-21
For Appellant: NoneFor Respondent: Shri Deepak Garg
Section 12ASection 2(15)

…the case of Fazlul Rabbi Pradhan vs. State of West Bengal, AIR 1965 SC 1722 clearly held that the religious activity also falls within the ambit and scope of charitable activities. Further, the Hon’ble Supreme Court in the case of CIT vs. Dawoodi Bohra Jamat, 364 ITR 31 also held that whereby the objects of the trust are mixed in nature i.e. religious, partly religious and partly non- religious the registration cannot be denied u/s 12AA of the Act. These ratio of the judgements was followed by us consistently in series of decisions of the Tribunal like in the case of Jain Shwetambar Mandir Trust vs. CIT (Exemptio…

Jain Shwetambar Mandirtrust, Pune vs. Commissioner of Income-Tax, (Exemptions), Pune

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

ITA 2901/PUN/2017[N.A]Status: DisposedITAT Pune03 Nov 2020

Bench: Shri Inturi Rama Rao, Am & Shri S. S. Viswanethra Ravi, Jm आयकर अपील सं. / Ita No.2901/Pun/2017 Jain Shwetambar Mandir Trust, At Post: Ghoti, Taluka: Igatpuri, District: Nashik. .......अपीलाथ" / Appellant Pan : Aabtj7192H बनाम / V/S. Cit (Exemptions), ……""यथ" / Respondent Pune. Assessee By : None Revenue By : Shri Shekhar L. Gajbhiye सुनवाई क" तारीख / Date Of Hearing : 03.11.2020 घोषणा क" तारीख / Date Of Pronouncement : 04.11.2020 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Trust Directed Against The Order Of The Ld. Commissioner Of Income Tax (Exemptions), Pune Dated 28.09.2017 Passed U/S 12Aa(1)(B)(Ii) Of The Income Tax Act, 1961 (For Short “The Act”) Denying The Registration U/S 12Aa Of The Act. 2. The Appellant Society Raised The Following Grounds Of Appeal :- “1. On The Basis Of Facts & In The Circumstances Of The Case & As Per Law, The Commissioner Of Income-Tax (Exemptions), Pune Is Not Justified In Not Granting Registration U/S 12Aa Of The Act To The Appellant Trust. 2. The Appellant Craves For Addition To, Alternation, Modification, Change Of The Above Ground Of Appeal.” 3. The Brief Facts Of The Case Are As Under :-

For Appellant: NoneFor Respondent: Shri Shekhar L. Gajbhiye
Section 11Section 12ASection 13(1)(b)

…that the exemption u/s 11 and 12 would not be available in case any income of trust or institution is created or established for the benefit of any particular religious, community or caste. The Hon’ble Supreme Court in the case of CIT vs. Dawoodi Bohra Jamat, 364 ITR 31 after exhaustively referring to the earlier precedent, held that where the objects of a trust are both charitable and religious, the trust shall be eligible for registration u/s 12AA of the Act. The section only requires to be established that such charitable purpose is not for the benefit of a particular religious community 4 or caste. That is t…

St. Francis Educational Trust, Chennai vs. ITO, Exemption Ward-2, Chennai

In the result, the appeal filed by assessee in ITA No

ITA 3395/CHNY/2019[2016-17]Status: DisposedITAT Chennai24 Aug 2020AY 2016-17

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy

For Appellant: Mr.AR.V.Sreenivasan, JCITFor Respondent: 20.07.2020
Section 11Section 12ASection 13(1)(c)Section 13(2)Section 143(3)

…wherein tribunal upheld order passed by AO denying assessee exemption u/s 11 owing to violation of Section 13(1)(c) and 13(1)(d) of the 1961 Act. The AO also relied upon decision of Hon’ble Supreme Court in the case of CIT v. Dawoodi Bohra Jamat reported in 364 ITR 31(SC) wherein exemption u/s 11 and 12 of the 1961 Act was denied to the asessee due to violation of Section 13(1)(c) of the Act. The assessee was assessed to tax by AO with status of AOP and assesee’s income was brought to tax at Maximum Marginal Rate as per proviso to Sec.164(2) of the 1961 Act, vide assessment order dated 14.12.2018 passed by A…

Maruti Mandir, Latur vs. Commissioner of Income-Tax, (Exemption), Pune

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

ITA 1131/PUN/2019[N.A]Status: DisposedITAT Pune17 Feb 2020

Bench: Shri George Mathan, Jm & Shri Anil Chaturvedi, Am

For Appellant: Shri M.K. KulkarniFor Respondent: Shri B.Kishore, CIT
Section 12A

…आयकर अपील"य अ"धकरण] पुणे "यायपीठ “ए” पुणे म" IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI GEORGE MATHAN, JM AND SHRI ANIL CHATURVEDI, AM आयकर अपील सं. / ITA No.1131/PUN/2019 Shri Maruti Mandir, ………. अपीलाथ" / Makni (Thor), Tal. Nilanga, Appellant Latur. PAN : AAETS5026Q. बनाम v/s The Commissioner of Income Tax, ………. ""यथ" / Exemption, Pune. Respondent Assessee by : Shri M.K. Kulkarni. Revenue by : Shri B.Kishore, CIT. सुनवाई क" तार"ख / घोषणा क" तार"ख / Date of Hearing : 13.02.2020 Date of Pronouncement: 17.02.2020 आदेश / ORDER PER ANIL CHATURVEDI, AM : This appeal filed by the a…

Ejipura Holy Christ Education Society, Bangalore vs. The Commissioner of Income Tax (Exemption), Bangalore

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1651/BANG/2017[2015-16]Status: DisposedITAT Bangalore07 Nov 2018AY 2015-16

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri Rajiv Nulvi, CAFor Respondent: Shri G. Guruswamy, CIT – DRP
Section 11Section 12ASection 2(15)Section 80GSection 80G(5)(vi)

…of trust having mixed objects of religious purposes and charitable purposes, registration u/s. 12A cannot be granted. In this regard, he placed reliance on the judgement of Hon’ble Apex Court rendered in the case of CIT Vs. Dawoodi Bohra Jamat as reported in 364 ITR 31 (SC) and pointed out that it was held by Hon’ble Apex Court in this case that if the primary purpose and the predominant object of a trust are to promote the welfare of the general public, the purpose would be charitable purpose and the issue was decided in favour of the assessee and the registration was granted. He submitted that in the present c…

Ejipura Holy Christ Education Society, Bangalore vs. CIT, Bangalore

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 738/BANG/2016[N.A.]Status: DisposedITAT Bangalore07 Nov 2018

Bench: Shri Sunil Kumar Yadav & Shri Arun Kumar Garodia

For Appellant: Shri Rajiv Nulvi, CAFor Respondent: Shri G. Guruswamy, CIT – DRP
Section 11Section 12ASection 2(15)Section 80GSection 80G(5)(vi)

…of trust having mixed objects of religious purposes and charitable purposes, registration u/s. 12A cannot be granted. In this regard, he placed reliance on the judgement of Hon’ble Apex Court rendered in the case of CIT Vs. Dawoodi Bohra Jamat as reported in 364 ITR 31 (SC) and pointed out that it was held by Hon’ble Apex Court in this case that if the primary purpose and the predominant object of a trust are to promote the welfare of the general public, the purpose would be charitable purpose and the issue was decided in favour of the assessee and the registration was granted. He submitted that in the present c…

M/S Annapurneshwari Anantha Ashrama Trust, Bangalore vs. The Deputy Director of Income Tax (E) Circle-17(2), Bangalore

In the result, the appeal of the assessee is allowed

ITA 1910/BANG/2017[2011-12]Status: DisposedITAT Bangalore24 Jan 2018AY 2011-12

Bench: Shri Arun Kumar Garodiaassessment Year : 2011-12

For Appellant: Shri T. Srinivasa, CAFor Respondent: Smt. Swapna Das, JCIT (DR)
Section 115BSection 12A

…the impugned order dated 20th August 2014 the ITAT while allowing the Assessee‟s appeal concluded, after discussing the relevant clauses of the Trust Deed as well as the decision of the Supreme Court in Commissioner of Income-Tax v. Dawoodi Bohra Jamat (2014) 364 ITR 31 (SC), that the AO and CIT had proceeded "on a very narrow and incorrect understanding in holding that the Assessee Trust was engaged in spreading spirituality and since Section 115BBC only exempts religious trust, a trust allegedly imparting spiritual knowledge was consequently not contemplated as an exception by the Legislature as much as it cons…

Regional Education Development Welfare Society, Gurgaon vs. CIT, Faridabad

The appeal of the assessee is allowed

ITA 6513/DEL/2014[]Status: DisposedITAT Delhi04 Oct 2017

Bench: Shri G.D. Agrawal, Hon’Ble & Shri Sudhanshu Srivastava

For Appellant: Shri Kapil Goel, AdvFor Respondent: Shri Atiq Ahmad, Sr. DR
Section 12ASection 143(3)Section 2(15)

…of IILM Foundation Academy, order dated 26.09.2016 (ITA no. 198/2011) ii. Hon’ble Kerala High Court decision in case of Sree Anjaneya Medical Trust reported in 382 ITR 399 iii. Hon’ble Supreme Court’s decision in the case of Dawoodi Bohara Jamat reported in 364 ITR 31. iv. Hon’ble Karnataka High Court decision in case of Sanjeevamma Hanumanthe Gowda Charitable Trust (285 ITR 327) v. Hon’ble Allahabad High Court decision in case of Fifth Generation Education Society (158 ITR 634) vi. Hon’ble Karnataka High Court decision in case of Garden City Education Trust (191 Taxman 238) vii. Hon’ble Punjab & Haryana High…

Imaan Foundation, Mumbai vs. CIT (E), Mumbai

In the result, appeal filed by the assessee is allowed

ITA 3168/MUM/2017[2012-13]Status: DisposedITAT Mumbai15 Sept 2017AY 2012-13

Bench: Shri P.K. Bansal, Vice- & Shri Pawan Singhm/S Imaan Foundation Cit(E) 6Th Floor, Piramal Chambers, S A Kanji (Ca) 206, Rewa Chambers, New Marine Vs. Lalbaug, Mumbai-400012. Lines, Mumbai-400020 Pan: Aaati0711L (Appellant) (Respondent)

For Appellant: Shri F. B. Andhyarujina (AR)For Respondent: Shri Rakesh Ranjan (DR)
Section 11Section 12ASection 13(1)(b)Section 143(2)Section 143(3)Section 253Section 254(1)Section 263Section 80G

…13(1)(b) of the Income Tax Act, 1961 are not applicable at all. ITA No.3168/M/2017- M/s Imaan Foundation (3) On the facts and circumstances and in law the learned CIT(E) misinterpreted the decision of the Supreme Court in CIT vs. Dawoodi Bohra Jamat (2014) 364 ITR 31/222 Taxman 228 (Mag)/43. Thus overlooking the fact that this is a debatable issue in which section 263 of the Income Tax Act, 1961 cannot be invoked. 2. Brief facts of the case are that the assessee is AOP/Trust claims to be a charitable organization and engaged in establishing, running and conducting Deeni Madresses in Mumbai or in India for adv…

Commissioner of Income Tax-(Exemptions) vs. M/S Indian Society of the Church of Jesus Christ of Latter Day Saints

The appeal is dismissed

ITA/319/2017HC Delhi07 Sept 2017

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MS. JUSTICE PRATHIBA M. SINGH

Section 11Section 12ASection 13Section 260A

…cular religious community." 10. The Assessee then went in appeal before the Commissioner of Income Tax (Appeals) [‘CIT(A)’]. The attention of the CIT(A) was drawn to the decision of the Supreme Court in Commissioner of Income Tax v. Dawoodi Bohra Jamat [2014] 364 ITR 31 (SC) which held on facts that the bar under Section 13 (1) (b) of the Act would not be applicable since the ITA 319/2017 Page 5 of 9 activities of the organization in that case served both religious and charitable purposes. The CIT (A) in the present case, however, decided not to apply the ratio of the Dawoodi Bohra Jamat (supra) on the ground t…

Ministry of Compassion India, Jaipur vs. Commissioner of Income Tax- Exemptions, Jaipur

In the result, both the appeals are allowed for statistical purposes

ITA 713/JPR/2015[2015-16]Status: DisposedITAT Jaipur15 Jun 2017AY 2015-16
For Appellant: Shri P.C. Parwal (C.A.)For Respondent: Shri Verindra Mehta (CIT)
Section 11Section 12ASection 13(1)Section 13(1)(b)Section 2(15)Section 80G(5)Section 80G(5)(vi)

…आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, JAIPUR Jh dqy Hkkjr] U;kf;d lnL; ,oa Jh foØe flag ;kno] ys[kk lnL; ds le{k BEFORE: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No.713/JP/15 fu/kZkj.k o"kZ@Assessment Year : cuke Ministry of Compassion India, The CIT (Exemptions), Vs. D-3/169, Chitrakoot, Vaishali Jaipur. Nagar, Jaipur LFkk;h ys[kk la-@thvkbZvkj la-@PAN No.: AABTM8172C vihykFkhZ@Appellant izR;FkhZ@Respondent vk;dj vihy la-@ITA No.714/JP/15 fu/kZkj.k o"kZ@Assessment Year : cuke Ministry of Compassion India, The CIT (Exemptions)…

Multan Jain Shwetamber Sabha, Jaipur vs. CIT (Exemption), Jaipur

In the result, application of the Assessee is dismissed

ITA 1060/JPR/2016[]Status: DisposedITAT Jaipur30 May 2017

Bench: The Date Of Hearing.”

For Appellant: Shri Vivek Chattar (CA)For Respondent: Shri D.S. Kothari (CIT)
Section 12ASection 13Section 13(1)

…), Jaipur ITA No. 742/JP/2015, Hon'ble Jaipur Bench of Tribunal in almost the similar facts had held that keeping the objects of the trust in view and respectfully following the judgment of the Hon'ble Supreme Court in the case of CIT v. Dawoodi Bohara Jamat, 364 ITR 31 (SC), the order of CIT (Exemption) is set 6 Shree Multan Jain Shwetamber Sabha. KundKundShikshan Kendra Trust v. CIT (Exemptions), Jaipur in ITA No. 905/JP/2016) order pronounced on 11 January, 2017 The facts are identical in the present case. Therefore, taking a consistent view, the Ld. CIT (Exemption) is hereby directed to grant registration u…

M/S. Pink Flowers Trust, Dehradun vs. CIT, Dehradun

In the result, the appeal of the assessee is allowed

ITA 3598/DEL/2014[]Status: DisposedITAT Delhi02 May 2017

Bench: : Shri Amit Shukla & Shri L.P. Sahu

For Appellant: 1. The Learned CIT has erred in law as well as on facts and circumstances of the
Section 12ASection 13Section 13(1)(b)Section 2(15)

…unity, which situation does not occur in the present case. Reliance is placed on the following decisions : (i). Kul Foundation vs. CIT (2015) 68 SOT 310 (ITAT Pune) (ii). Diocese of Pune(CN) vs. CIT 68 SOT 555 (ITAT Pune) (iii). CIT vs. Dawoodi Bohara Jamat, 364 ITR 31 (SC). 4. On the other hand, the ld. DR relied on the order of the ld. CIT and urged for its sustenance. 5. We have considered the rival submissions and have perused the entire material available on record. From the composite reading of objects of the Trust, we find that the assessee trust is not established solely for giving benefit to a particu…

Lokmanya Tilad Janakalya Shikshan Sanstha, Nagpur vs. Assistant Commissioner of Income Tax Circle -2, Nagpur

In the result, this appeal by the assessee stands partly allowed

ITA 384/NAG/2012[2008-09]Status: DisposedITAT Nagpur09 Jan 2017AY 2008-09

Bench: Shri Shamim Yahya & Shri Ram Lal Negi..

For Appellant: Shri K.P. DewaniFor Respondent: Shri A.R. Ninawe
Section 1Section 11Section 13(1)(c)Section 13(3)Section 40

…1 IN THE INCOME TAX APPELLATE TRIBUNAL, NAGPUR BENCH, NAGPUR BEFORE SHRI SHAMIM YAHYA, ACCOUNTANT MEMBER AND SHRI RAM LAL NEGI, JUDICIAL MEMBER.. I.T.A. No. 384/Nag/2012 Assessment Year : 2008-09. Lokmanya Tilak Janakalyan Asstt. Commissioner of Income-tax, Shikshan Sanstha, Nagpur. Vs. Circle-2, Nagpur. PAN AAATL3003C. Appellant. Respondent. Appellant by : Shri K.P. Dewani. Respondent by : Shri A.R. Ninawe. Date of Hearing : 22-11-2016 Date of Pronouncement : 9th January, 2017. O R D E R. PER SHAMIM YAHYA, A.M. : This appeal by the assessee is directed against the order of learned CIT(Appeals)- I, Nagpur date…

The Dubaria Parivar Charitable Trust, Mumbai vs. DIT (E), Mumbai

In the result, the appeal filed by the applicant is allowed

ITA 4890/MUM/2013[2013-14]Status: DisposedITAT Mumbai26 Aug 2016AY 2013-14

Bench: Shri Saktijit Dey() & Shri N.K. Pradhan () The Dubaria Parivar Charitabl Trust Vs. Dit(E) 75 Mint Rd, Shreeji House 6Th Floor, 3Rd Floor, Fort Piramal Chambers Mumbai- 400001 Parel, Mumbai-400012

For Appellant: Shri. Harsh R. ShahFor Respondent: Shri. B. Jaya Kumar
Section 12Section 12A

…rial placed on record before us. We have gone through the objects of trust. We find that a large portion of the objects aims to achieve charitable purposes. Only a few objects are meant for religious purposes. In the case of CIT vs. Dawoodi Bohra Jamat (2014) 364 ITR 31 (SC), it is held that when the objects of the assessee are not indicating of a wholly religious purpose but are collectively indicative of both charitable and religious purposes, exemption cannot be denied. Therefore, registration cannot be denied to the trust on the above ground. In the instant appeal, the objects of the applicant are collectivel…

Ahimsa Parmo Dharma Trust, Mumbai vs. DIT (E), Mumbai

In the result, appeal of assessee is allowed

ITA 6778/MUM/2014[]Status: DisposedITAT Mumbai08 Jun 2016
For Appellant: Shri Vimal PunmiyaFor Respondent: Awungshi Gimson
Section 12A

…charitable trust. However, at the time of grant of registration director of Exemption is required to verify only the object of the trust and whether the activities of trust are genuineness. The Hon’ble Supreme Court in the case of Dawoodi Boharh Jamat [2014] 364 ITR 31 (SC), held that the respondent-trust is a charitable and religious trust which does not benefit any specific religious community and therefore, it cannot be held that Section 13(1)(b) of the Act would be attracted to the respondent-trust and thereby, it would be eligible to claim exemption under Section 11 of the Act. Hence, registration required…

Ramachand Motichand Shah Educational & Cultural Trust, Bijapur vs. CIT, Belgaum

In the result, the appeal filed by the assessee is allowed

ITA 924/BANG/2014[N.A.]Status: DisposedITAT Bangalore09 Oct 2015

Bench: Shri Vijaypal Rao & Shri Jason P Boazramachand Motichand Shah Educational & Cultural Trust, Sunita Nivas, Bijapur Road, Indi Bijapur-586 209. . Appellant Vs. The Commissioner Of Income-Tax, Belgaum. . Respondent Appellant By : Shri Ramasubramaniyan, Ca Respondent By : Shri Saravanan, Jcit Date Of Hearing : 15-09-2015 Date Of Pronouncement : 09-10-2015 O R D E R

For Appellant: Shri Ramasubramaniyan, CAFor Respondent: Shri Saravanan, JCIT
Section 11Section 12ASection 13Section 80G

…encourage the study of research in all forms of ancient Indian system of thought philosophies, ayurvedic medicine, yoga etc. In support of his contention he has relied upon the judgment of Hon’ble Supreme Court in the case of CIT Vs. Dawoodi Bohra Jamat, 364 ITR 31 and submitted that the Hon’ble Supreme Court has observed that the object of the assessee were collectively inclusive of both charitable and religious purpose and not only religious purpose. Therefore, when it was found that objects of the assessee was to provide assistance to ITA No.924/B/14 5 needy and poor for religious activity would not d…