DIT v. Sabarmati Gaushala Trust

362 ITR 539High Court2014#1798 most cited

What is DIT v. Sabarmati Gaushala Trust authority for?

Activities of a trust established for the advancement of general public utility do not constitute a 'business' activity if undertaken without private motive, thus qualifying for exemption under Section 11 read with Section 2(15), even when charging fees or receiving consideration.

63

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2016 to 2026.

Also referred to as

DIT v. Sabarmati Gaushala Trust · Section 11 · Section 2(15) · charitable purpose · advancement of general public utility · business activity · private motive · proviso to Section 2(15) · income exemption · fees for services · subscriptions · publications

Sections most often in play

Section 11Section 2(15)Section 12Section 12ASection 143(3)

Issues it is cited on

section 4(3)section 205advancement of general public utilitysection 36(1)(v)section 10(23c)(iv)section 52proviso to section 2(15)section 11(4a)mlisection 2(15)section 10(23c)put to use

Judgments citing DIT v. Sabarmati Gaushala Trust

M/S U.P Awas Evam Vikas Parishad, Lucknow vs. Deputy Commissioner of Income Tax (Exemption), Lucknow

In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes

ITA 165/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Jun 2022AY 2015-16

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12Section 12ASection 13(8)Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 24/LKW/2017[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 23/LKW/2017[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 211/LKW/2017[2014-15]Status: DisposedITAT Lucknow08 Jun 2022AY 2014-15

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 210/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Jun 2022AY 2013-14

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 165/LKW/2017[2012-13]Status: DisposedITAT Lucknow08 Jun 2022AY 2012-13

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 164/LKW/2017[2011-12]Status: DisposedITAT Lucknow08 Jun 2022AY 2011-12

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 631/LKW/2016[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 630/LKW/2016[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

Bench: Shri A. D. Jain & Shri T. S. Kapoor

Section 11Section 12ASection 143(3)Section 15Section 2(15)

…usively meant for a particular religious community. The objects do not channel benefit of any community hence would not fall under the ambit of Section 13(1)(b) of Act, 1961. 46. In Director of Income Tax (Exemption) Vs. Sabarmati Ashram Gaushala Trust [2014] 362 ITR 539 (Gujarat), after looking into the documents relating to insertion of proviso in Section 2(15) of Act, 1961, Court said that activity of a trust would be excluded from the term ''charitable purpose', if it is engaged in any activity in the nature of trade, commerce or business or any service in relation to trade commerce or business for a cess, fe…

DCIT(E)-2(1), Mumbai vs. Nehru Centre, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 7461/MUM/2018[2010-11]Status: DisposedITAT Mumbai04 Feb 2022AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Bledcit (E) – 2(1) V. Nehru Centre Room No. 519, 5Th Floor Discovery Of India Building Piramal Chambers, Lalbaug 13Th Floor, Dr. Annie Besant Road Worli, Mumbai - 400018 Mumbai – 400 012 Pan: Aaatn2536J (Appellant) (Respondent) Assessee By : Shri Dilip Thakkar Department By : Shri Dilipkumar Shah

For Appellant: Shri Dilip ThakkarFor Respondent: Shri Dilipkumar Shah
Section 11Section 143(2)Section 2(15)

…ed 31% March 2010. Further, on this subject, the analysis of the proviso to section 2(15), the Finance Minister's speech in the Parliament and CBDTs clarification as discussed by the Hon'ble High Court of Gujarat in the case of Sabarmati Ashram Gaushala Trust 362 ITR 539 is mentioned herein below: a “4. Term "Charitable Trust" is defined in Section 2(15) of the Act which includes the relief to the poor, education, medical relief, preservation of environment; including watersheds, forests and wildlife and preservation of monuments or places or objections of 32 Nehru Centre artistic or historic interest and advance…

Mumbai Metroplitan Region Development Authority, Mumbai vs. DDIT (E) -1(1), Mumbai

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

ITA 4395/MUM/2019[2015-16]Status: DisposedITAT Mumbai03 Jan 2022AY 2015-16

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Saurabh SoparkarFor Respondent: Shri Parag Vyas
Section 10Section 10(20)Section 11Section 12Section 12ASection 143(2)Section 143(3)

…retention of such income from such activity will be immaterial." 7. The Appellant also relies on the following other decisions of the High Courts and the Tribunals to support the proposition of the Appellant. 1 Sabarmati Ashram Gaushala Trust Vs Asst DIT(E) (362 ITR 539) (Guj HC) 2 GS1 India v. DGIT(E)(360 ITR 138)(Del HC) 3 Moradabad Development Authority v. ACIT (E)(168 ITD 564 4 Bangalore Development Authority v. ACIT (176 ITD 833) 5 Hoshiarpur Improvement Trust v. ITO (155 ITD 570) 6 Gujarat Cricket Association v. JCIT (E) (101 taxmann.com 453) 7 Surat Urban Development Authority v. DCIT (E)(182 ITD 20) 8 Jh…

Mumbai Metroplitan Region Development Authority, Mumbai vs. DDIT (E) -1(1), Mumbai

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

ITA 4394/MUM/2019[2014-15]Status: DisposedITAT Mumbai03 Jan 2022AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Saurabh SoparkarFor Respondent: Shri Parag Vyas
Section 10Section 10(20)Section 11Section 12Section 12ASection 143(2)Section 143(3)

…retention of such income from such activity will be immaterial." 7. The Appellant also relies on the following other decisions of the High Courts and the Tribunals to support the proposition of the Appellant. 1 Sabarmati Ashram Gaushala Trust Vs Asst DIT(E) (362 ITR 539) (Guj HC) 2 GS1 India v. DGIT(E)(360 ITR 138)(Del HC) 3 Moradabad Development Authority v. ACIT (E)(168 ITD 564 4 Bangalore Development Authority v. ACIT (176 ITD 833) 5 Hoshiarpur Improvement Trust v. ITO (155 ITD 570) 6 Gujarat Cricket Association v. JCIT (E) (101 taxmann.com 453) 7 Surat Urban Development Authority v. DCIT (E)(182 ITD 20) 8 Jh…

Mumbai Metroplitan Region Development Authority, Mumbai vs. DDIT (E) -1(1), Mumbai

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

ITA 4393/MUM/2019[2013-14]Status: DisposedITAT Mumbai03 Jan 2022AY 2013-14

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Saurabh SoparkarFor Respondent: Shri Parag Vyas
Section 10Section 10(20)Section 11Section 12Section 12ASection 143(2)Section 143(3)

…retention of such income from such activity will be immaterial." 7. The Appellant also relies on the following other decisions of the High Courts and the Tribunals to support the proposition of the Appellant. 1 Sabarmati Ashram Gaushala Trust Vs Asst DIT(E) (362 ITR 539) (Guj HC) 2 GS1 India v. DGIT(E)(360 ITR 138)(Del HC) 3 Moradabad Development Authority v. ACIT (E)(168 ITD 564 4 Bangalore Development Authority v. ACIT (176 ITD 833) 5 Hoshiarpur Improvement Trust v. ITO (155 ITD 570) 6 Gujarat Cricket Association v. JCIT (E) (101 taxmann.com 453) 7 Surat Urban Development Authority v. DCIT (E)(182 ITD 20) 8 Jh…

Mumbai Metroplitan Region Development Authority, Mumbai vs. DDIT (E) -1(1), Mumbai

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

ITA 4392/MUM/2019[2012-13]Status: DisposedITAT Mumbai03 Jan 2022AY 2012-13

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Saurabh SoparkarFor Respondent: Shri Parag Vyas
Section 10Section 10(20)Section 11Section 12Section 12ASection 143(2)Section 143(3)

…retention of such income from such activity will be immaterial." 7. The Appellant also relies on the following other decisions of the High Courts and the Tribunals to support the proposition of the Appellant. 1 Sabarmati Ashram Gaushala Trust Vs Asst DIT(E) (362 ITR 539) (Guj HC) 2 GS1 India v. DGIT(E)(360 ITR 138)(Del HC) 3 Moradabad Development Authority v. ACIT (E)(168 ITD 564 4 Bangalore Development Authority v. ACIT (176 ITD 833) 5 Hoshiarpur Improvement Trust v. ITO (155 ITD 570) 6 Gujarat Cricket Association v. JCIT (E) (101 taxmann.com 453) 7 Surat Urban Development Authority v. DCIT (E)(182 ITD 20) 8 Jh…

Mumbai Metroplitan Region Development Authority, Mumbai vs. DDIT (E) -1(1), Mumbai

In the result, appeal filed by the assessee is partly allowed and revenue is dismissed

ITA 4391/MUM/2019[2010-11]Status: DisposedITAT Mumbai03 Jan 2022AY 2010-11

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Pavan Kumar Gadale, Hon'Ble

For Appellant: Shri Saurabh SoparkarFor Respondent: Shri Parag Vyas
Section 10Section 10(20)Section 11Section 12Section 12ASection 143(2)Section 143(3)

…retention of such income from such activity will be immaterial." 7. The Appellant also relies on the following other decisions of the High Courts and the Tribunals to support the proposition of the Appellant. 1 Sabarmati Ashram Gaushala Trust Vs Asst DIT(E) (362 ITR 539) (Guj HC) 2 GS1 India v. DGIT(E)(360 ITR 138)(Del HC) 3 Moradabad Development Authority v. ACIT (E)(168 ITD 564 4 Bangalore Development Authority v. ACIT (176 ITD 833) 5 Hoshiarpur Improvement Trust v. ITO (155 ITD 570) 6 Gujarat Cricket Association v. JCIT (E) (101 taxmann.com 453) 7 Surat Urban Development Authority v. DCIT (E)(182 ITD 20) 8 Jh…

ITO (Exemption), Ward, Surat vs. Gujarat Hira Bourse, Surat

In the result, appeals filed by the Revenue (in ITA No

ITA 190/SRT/2020[2017-18]Status: DisposedITAT Surat31 Dec 2021AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 11Section 11(1)(a)Section 13Section 13(8)Section 2(15)Section 254(1)

…ng of service to trade, commerce or business' must be such that it has a profit motive. 23.On similar and identical facts the reliance can be placed on the decision of Hon'ble Gujarat High Court, in the case of DIT vs. Sabarmati Gaushala Aashram Trust [2014] 362 ITR 539, wherein at para no. 9 of the judgment Hon'ble High Court observed that many activities of genuine charitable purposes which are not in the nature of trade, commerce or business may still generate marketable products. After setting off of the cost, for production of such marketable products from the sale consideration, the activity may leave a su…

ITO (Exemption) Ward, Surat vs. Gujarat Hira Bourse, Surat

In the result, appeals filed by the Revenue (in ITA No

ITA 189/SRT/2020[2014-15]Status: DisposedITAT Surat31 Dec 2021AY 2014-15

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 11Section 11(1)(a)Section 13Section 13(8)Section 2(15)Section 254(1)

…ng of service to trade, commerce or business' must be such that it has a profit motive. 23.On similar and identical facts the reliance can be placed on the decision of Hon'ble Gujarat High Court, in the case of DIT vs. Sabarmati Gaushala Aashram Trust [2014] 362 ITR 539, wherein at para no. 9 of the judgment Hon'ble High Court observed that many activities of genuine charitable purposes which are not in the nature of trade, commerce or business may still generate marketable products. After setting off of the cost, for production of such marketable products from the sale consideration, the activity may leave a su…

All India Photographic Trade and Industry Association, Mumbai vs. ITO (E)-1(1), Mumbai

The appeal of the assessee is allowed in terms of our observations recorded hereinabove

ITA 1705/MUM/2019[2014-15]Status: DisposedITAT Mumbai04 Mar 2021AY 2014-15

Bench: Sri Rajesh Kumar, Am & Sri Amarjit Singh, Jm आमकय अऩीर सं./ Ita No. 1387/Mum/2020 (यनधाायण वषा / Assessment Years 2013-14) आमकय अऩीर सं./ Ita No. 1705/Mum/2019 (यनधाायण वषा / Assessment Years 2014-15) All India Photographic Trade & The Income Tax Officer(E) Industry Association Ward 1(1), Mumbai 1 S T C-3/6, Taj Building, 210, फनाभ/ Floor, Dr. D.N. Road, Fort, Vs. Mumbai (अऩीराथी / Appellant) (प्रत्मथी/ Respondent) स्थामी रेखा सं./Pan No. Aaaaa0042K अऩीराथी की ओय से/ Appellant By : Shri Kirit Sanghvi, Ar प्रत्मथी की ओय से/ Respondent By : Shri Brajendra Kumar, Dr सुनवाई की तायीख / Date Of Hearing: 22.12.2021 घोषणा की तायीख / Date Of Pronouncement: 04.03.2021

For Appellant: Shri Kirit Sanghvi, ARFor Respondent: Shri Brajendra Kumar, DR
Section 11Section 12ASection 143(3)Section 2(15)

…ation of Real Estate Developers Association of India Vs. CIT(A)-3 other consideration. We find that our aforesaid view is fortified by the judgment of the Hon'ble High Court of Gujarat in the case of DIT (Eexemption) Vs. Sabarmati Ashram Gaushala Trust (2014) 362 ITR 539 (Guj). ITA Nos. 1387/M/20 & 1705/M/19 Page No. 28 12. We thus in the backdrop of our aforesaid observations are of the considered view that the assessee trust was set up for a charitable purpose within the meaning of Sec. 2(15) of the Act, viz. advancement of an object of the general public utility. We are of the view that as had been deliberate…

Confederation of Real Estate Developers of India, Mumbai vs. CIT (A)- 3, Mumbai

The appeal of the assessee is allowed in terms of our observations recorded hereinabove

ITA 2815/MUM/2018[2014-15]Status: DisposedITAT Mumbai15 Sept 2020AY 2014-15

Bench: Shri M. Balaganesh & Shri Ravish Soodconfederation Of Real Estate Acit (Exemption)-1(1), Developers Association Of India, Piramal Chambers, Lalbaug, 5Th Floor, Phd House, Vs. Parel, Mumbai 400 012 4/2, Siri Insitutional Area, New Delhi-110016

For Appellant: Shri Jitendra Jain &For Respondent: Shri. Kumar Padmapani Bora &
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 25Section 8

…ation of Real Estate Developers Association of India Vs. CIT(A)-3 other consideration. We find that our aforesaid view is fortified by the judgment of the Hon’ble High Court of Gujarat in the case of DIT (Eexemption) Vs. Sabarmati Ashram Gaushala Trust (2014) 362 ITR 539 (Guj). 12. We thus in the backdrop of our aforesaid observations are of the considered view that the assessee trust was set up for a charitable purpose within the meaning of Sec. 2(15) of the Act, viz. advancement of an object of the general public utility. We are of the view that as had been deliberated by us at length hereinabove, the holding o…

Confederation of Real Estate Developers Associaton of India, New Delhi vs. ACIT (Exem)-1(1), Mumbai

The appeal of the assessee is allowed in terms of our observations recorded hereinabove

ITA 6896/MUM/2019[2016-17]Status: DisposedITAT Mumbai15 Sept 2020AY 2016-17

Bench: Shri M. Balaganesh & Shri Ravish Soodconfederation Of Real Estate Acit (Exemption)-1(1), Developers Association Of India, Piramal Chambers, Lalbaug, 5Th Floor, Phd House, Vs. Parel, Mumbai 400 012 4/2, Siri Insitutional Area, New Delhi-110016

For Appellant: Shri Jitendra Jain &For Respondent: Shri. Kumar Padmapani Bora &
Section 11Section 12ASection 143(2)Section 143(3)Section 2(15)Section 25Section 8

…ation of Real Estate Developers Association of India Vs. CIT(A)-3 other consideration. We find that our aforesaid view is fortified by the judgment of the Hon’ble High Court of Gujarat in the case of DIT (Eexemption) Vs. Sabarmati Ashram Gaushala Trust (2014) 362 ITR 539 (Guj). 12. We thus in the backdrop of our aforesaid observations are of the considered view that the assessee trust was set up for a charitable purpose within the meaning of Sec. 2(15) of the Act, viz. advancement of an object of the general public utility. We are of the view that as had been deliberated by us at length hereinabove, the holding o…