DIT (Exemptions) v. Gujarat Cricket Association

MADHAV UNIVERSITY,PINDWARA, SIROHI vs. CIT(EXEMPTION), JAIPUR

In the result, both the appeals filed by the assessee bearing ITA No

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α No.789 &790/Jodh/2024 (Assessment Year:2024-25) Madhav University Vs Commissioner Of Income-Tax, Exemption, Jaipur Pindwara, Madhav Hills, Nh 27, Vpo Bharja, Pindwara, Sirohi Rajasthan-307023 Pan: Aasam7855L Shri Amit Kothari Shri M.K. Jain, Cit(Dr.) Present For Assessee Present For Revenue Date Of Hearing 20/08/2025 Date Of Pronouncement 22/08/2025 Order Per Bench: The Instant Appeals Of The Assessee Filed Against The Order Of The Learned Commissioner Of Income-Tax (Exemption), Jaipur (For Brevity, 'Ld.Cit(E)'] Order Passed Under Section 12Ab Of The Income-Tax Act, 1961 (In Short, 'The Act') & Order Passed Under Section 80G(5) Of The Act, Date Of Orders 30/09/2024. 2. Act Both The Appeals Related To Registration Under Section 12Ab& 80G Of The

…ct legal entity and is only the sponsoring body. 3.2. Madhav University commenced operations independently on 1.04.2023. 3.3. Reliance is placed on the decision in the case of Director of Income ax Exemptions vs. Gujarat Cricket Association reported in (2019) 419 ITR 561 (Guj) primary object test applies to the assessee, not related entities. 4. Surplus Does Not Equal Profit Motive 4.1. Surplus was incidental, fully ploughed back into educational infrastructure, scholarships, and academic programs. 4.2. Financial trend from FY 2020-21 to 2023-24: Year Total Income Total % of Income Capital expenditure Applied exp…