Institute of Chartered Accountants of India (ICAI) v. DGIT (Exemptions)

358 ITR 91High Court2013#1419 most cited

What is Institute of Chartered Accountants of India (ICAI) v. DGIT (Exemptions) authority for?

An institution carrying out charitable objects, such as education or advancement of general public utility, does not lose its Section 11 exemption merely by collecting fees for activities like campus placements or educational guidance, as this does not constitute carrying on a business.

80

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

Institute of Chartered Accountants of India v DGIT Exemptions · 358 ITR 91 · Section 11 exemption · Section 2(15) proviso · charitable purpose · carrying on business · fees for services · campus placements · educational institutions · advancement of general public utility · income tax exemption · Delhi High Court

Sections most often in play

Section 11Section 2(15)Section 12Section 11(1)(d)Section 13(8)Section 10(23C)Section 11(1)(a)Section 11(4A)

Issues it is cited on

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

Judgments citing Institute of Chartered Accountants of India (ICAI) v. DGIT (Exemptions)

DCIT(E) 2(1), MUMBAI vs. SRI SHANMUKHANANDA FINE ARTS & SANGEETHA SABHA, MUMBAI

In the result, both appeals filed by assessee Revenue stands dismissed

ITA 9385/MUM/2025[2016]Status: DisposedITAT Mumbai10 Apr 2026

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 11Section 13(8)Section 2(15)Section 260A

…the charitable activities are by product, as alleged by the departmental authorities. What has to seen in such cases is a holistic view of the things and not a narrower view. We would like to refer to the matter of Institute of Chartered Accountants of India (358 ITR 91) wherein the Hon’ble Delhi High Court has held as under:- “A plain reading of section 2(15) of the Income-tax Act, 1961, indicates that the expression “charitable purpose” has been divided into six categories, namely, (i) relief to poor, (ii) education, 11 I.T.A. No. 9383/Mum/2025 & I.T.A. No. 9384/Mum/2025 (iii) medical relief, (iv) preservatio…

DCIT(E) 2(1), MUMBAI vs. SRI SHANMUKHANANDA FINE ARTS & SANGEETHA SABHA, MUMBAI

In the result, both appeals filed by assessee Revenue stands dismissed

ITA 9384/MUM/2025[2015]Status: DisposedITAT Mumbai10 Apr 2026

Bench: Smt. Beena Pillai () & Shri Jagadish ()

Section 11Section 13(8)Section 2(15)Section 260A

…the charitable activities are by product, as alleged by the departmental authorities. What has to seen in such cases is a holistic view of the things and not a narrower view. We would like to refer to the matter of Institute of Chartered Accountants of India (358 ITR 91) wherein the Hon’ble Delhi High Court has held as under:- “A plain reading of section 2(15) of the Income-tax Act, 1961, indicates that the expression “charitable purpose” has been divided into six categories, namely, (i) relief to poor, (ii) education, 11 I.T.A. No. 9383/Mum/2025 & I.T.A. No. 9384/Mum/2025 (iii) medical relief, (iv) preservatio…

DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION)-1(1), MUMBAI, MUMBAI vs. ALL INDIA GEM AND JEWELLERY DOMESTIC COUNCIL, MUMBAI

In the result, the appeal of the Revenue is dismissed

ITA 4652/MUM/2025[2015-16]Status: DisposedITAT Mumbai24 Dec 2025AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2015-16

For Respondent: Mr. Firoz Andhyarujina
Section 11Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI RAJ KUMAR CHAUHAN (JUDICIAL MEMBER) Assessment Year: 2015-16 Dy. CIT (Exemption)-1(1), All India Gem And Jewellery 6th floor, MTNL Building Domestic Council, Vs. Cumballa Hill, Dr. GD 1501 & 1502, Panchratna CHS Deshmukh Marg (Pedder Ltd. P Marg, Opera House, Road), Charni Road (East), Mumbai-400026. Mumbai-400 004. PAN NO. AAFCA 3001 P Appellant Respondent : Mr. Firoz Andhyarujina Assessee by Revenue by : Mr. Surendra Mohan, Sr. DR : 01/10/2025 Date of Hearing Date of pronouncement : 24/12/20…

CREDIT GUARANTEE FUND TRUST FOR MICRO AND SMALL ENTERPRISES ,MUMBAI vs. DCIT EXEMPTION-1(1), MUMBAI

In the result the appeal filed by the assessee stands allowed for statistical purposes

ITA 179/MUM/2025[2015-16]Status: DisposedITAT Mumbai06 Mar 2025AY 2015-16

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Prabhash Shankarcredit Guarantee Fund Vs. Dcit(E) – 1(1) Trust Mumbai. 1St Floor, Sidbi Swavalaman Bhavan, Avenue – 3, Lane 2, G-Block, Bkc, Bandra (E) Pan/Gir No. Aaatc2613D (Applicant) (Respondent)

Section 11(1)(a)Section 11(1)(d)Section 12ASection 143(1)Section 2(24)Section 2(24)(iia)Section 250

…ax (Exemptions) [2015] 53 taxmann.com 404 (Delhi). b) S1 India v. Director General of Income-tax (Exemption) [2013] 38 taxmann.com 364 (Delhi) where High Court of Delhi has held that that c) The Institute of Chartered Accountants of India Vs DGIT (E) [(2013) 358 ITR 91]. d) Army Welfare Placement Organization v. DIT (Exemptions), New Delhi [2015] 53 taxmann.com 442 (Delhi - Trib.) e) ACIT, Gujarat vs. Surat Art Silk Cloth Manufacturers Association (SC) 121 ITR 1 4.4 Without prejudice to the above:-It is submitted that the main objects pursued by the trust is rendering services to that section of society which…

DCIT CIRCLE -1 (EXEMPTION) AHMEDABAD, AHMEDABAD vs. NARODA ENVIRO PROJCT LIMITED , AHMEDABAD

In the result, appeal of the Revenue is dismissed

ITA 360/AHD/2024[2016 17]Status: DisposedITAT Ahmedabad29 May 2024

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 11Section 12ASection 143Section 2(15)Section 25

…of Indian Automobile Manufactures vs. ITO, Delhi). 6.3. The Division Bench further relying upon the judgment of the Delhi High Court in the case of Institute of Chartered Accountants of India vs. Director General of Income Tax (Exemptions) reported in (2013) 358 ITR 91 has observed thus: 92. The Delhi High Court in the Institute of Chartered Accounts of India v. Director General of Income-tax (Exemptions), [2013] 358 ITR 91/217 Taxman 152/35 taxmann.com 140 (Delhi) observed, while disposing of a writ petition, that holding interviews for fees for the purpose of campus placements of its students does not amount t…

HIMACHAL PRADESH TECHNICAL UNIVERSITY ,HAMIRPUR vs. CIT(E), CHANDIGARH

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

ITA 115/CHANDI/2020[-]Status: DisposedITAT Chandigarh28 Mar 2024

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. VIKRAM SINGH YADAV (Accountant Member)

For Appellant: Shri Amitoz Singh Kamboj, CAFor Respondent: Shri Rohit Sharma, CIT DR
Section 10

…arged from the students at the time of admission in order to guide them about the right stream to be taken by them and in support, reliance was placed on the decision of Hon’ble Delhi High Court in case of Institute of Chartered Accountants of India Vs. DGIT 358 ITR 91 (2013). 21. Regarding University Development fund, it was submitted that these funds are transferred to the Corpus and the same cannot be utilized for any other purpose other than the development of the University and these funds are created for specific purposes. Regarding the observation of the Ld. CIT(E) that no proof regarding utilization of…

CONFRERE EDUCATIONAL SOCIETY,NOIDA vs. ITO (EXEMPTION), NOIDA

In the result, the appeal of the assessee is allowed

ITA 4464/DEL/2017[2012-13]Status: DisposedITAT Delhi19 Jun 2023AY 2012-13

Bench: Sh. Anil Chaturvedi & Sh. Anubhav Sharma

Section 12ASection 250Section 251Section 56

…tate of Gujarat. Therefore, they are entitled to be registered as 'Charitable Trust' under section 12A of the 1961 Act.” 20. This principle has been reiterated by the Hon'ble Delhi High Court in the case of Institute of Chartered Accountants of India- v-DGIT, 358 ITR 91 (Del). Thus, the assessee society which has been registered under ‘Registration of Societies Act, 1860’ with the sole object of providing education and has a legal obligation for applying its income for such charitable purpose, then for the purpose of Section 11 it has to be treated as trust and income derived from carrying out such obligation has…

ASSOCIATION OF MUTUAL FUNDS IN INDIA,MUMBAI vs. DCIT(E)-1(1), MUMBAI

In the result, the present appeal is allowed

ITA 5761/MUM/2015[2012-13]Status: DisposedITAT Mumbai06 Sept 2022AY 2012-13
For Appellant: Shri Samir Kapadia/ Nitesh JoshiFor Respondent: Shri Milind Chavan/ Mehul Jain
Section 11Section 12ASection 143(3)Section 2(15)Section 25

…& 6888/Mum/2016 Assessment Years: 2011-12, 2012-13 & 2013-14 Representative for the Appellant. The relevant extract of the aforesaid judgment read as under: “18. We may also refer to another decision of the Delhi High Court in ICAI v. DGIT (Exemption) [2013] 358 ITR 91 (Delhi), where the Court observed at para 67 thereof as under :— 'The expressions "trade", "commerce" and "business", as occurring in the first proviso to section 2(15) of the Act, must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised man…

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 948/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 947/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2089/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2088/BANG/2018[2012-13]Status: DisposedITAT Bangalore16 Jun 2022AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2087/BANG/2018[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2086/BANG/2018[2010-11]Status: DisposedITAT Bangalore16 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 1962/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

…ons Fund's case (supra) can be applied. The six indicia stipulated in Lord Fisher's case (supra) are also relevant. Each case, therefore, has to be examined on its own facts. ∗ In Institute of Chartered Accountants of India (ICAI) vs. DGIT (Exemptions) [2012] 358 ITR 91 (Delhi), it was held as follows: 67. The expressions "trade", "commerce" and "business" as occurring in the first proviso to section 2(15) of the Act must be read in the context of the intent and purport of section 2(15) of the Act and cannot be interpreted to mean any activity which is carried on in an organised manner. The purpose and the domin…

JAIBHARAT MANDAL RAMLILA AND DHARAMSHALA SOCIETY,HISAR vs. ITO (EXEMPTION), ROHTAK

ITA 291/DEL/2020[2016-17]Status: DisposedITAT Delhi23 Mar 2022AY 2016-17

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…ve been held to be charitable because there is no profit motive. Reliance in this regard is placed on the decision of the hon’ble Delhi High Court in the case of Institute of Chartered Accountants of India v. Director General of Income-tax (Exemptions) [2013] 358 ITR 91 (Delhi). The objects of the society provide clearly that income of the society if any is to be used for the objects of the society and no portion thereof is to be transferred to the members directly or indirectly. Further the members are also barred from being appointed to any salaried office of the society. In regard thereof, no activity being c…

JAIBHARAT MANDAL RAMLILA AND DHARAMSHALA SOCIETY,HISAR vs. ITO (EXEMPTION), ROHTAK

ITA 5277/DEL/2019[2014-15]Status: DisposedITAT Delhi23 Mar 2022AY 2014-15

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…ve been held to be charitable because there is no profit motive. Reliance in this regard is placed on the decision of the hon’ble Delhi High Court in the case of Institute of Chartered Accountants of India v. Director General of Income-tax (Exemptions) [2013] 358 ITR 91 (Delhi). The objects of the society provide clearly that income of the society if any is to be used for the objects of the society and no portion thereof is to be transferred to the members directly or indirectly. Further the members are also barred from being appointed to any salaried office of the society. In regard thereof, no activity being c…

JAIBHARAT MANDAL RAMLILA AND DHARAMSHALA SOCIETY,HISAR vs. ITO (EXEMPTION), ROHTAK

ITA 5276/DEL/2019[2012-13]Status: DisposedITAT Delhi23 Mar 2022AY 2012-13

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…ve been held to be charitable because there is no profit motive. Reliance in this regard is placed on the decision of the hon’ble Delhi High Court in the case of Institute of Chartered Accountants of India v. Director General of Income-tax (Exemptions) [2013] 358 ITR 91 (Delhi). The objects of the society provide clearly that income of the society if any is to be used for the objects of the society and no portion thereof is to be transferred to the members directly or indirectly. Further the members are also barred from being appointed to any salaried office of the society. In regard thereof, no activity being c…

JAIBHARAT MANDAL RAMLILA AND DHARAMSHALA SOCIETY,HISAR vs. ITO (EXEMPTION), ROHTAK

ITA 5275/DEL/2019[2010-11]Status: DisposedITAT Delhi23 Mar 2022AY 2010-11

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…ve been held to be charitable because there is no profit motive. Reliance in this regard is placed on the decision of the hon’ble Delhi High Court in the case of Institute of Chartered Accountants of India v. Director General of Income-tax (Exemptions) [2013] 358 ITR 91 (Delhi). The objects of the society provide clearly that income of the society if any is to be used for the objects of the society and no portion thereof is to be transferred to the members directly or indirectly. Further the members are also barred from being appointed to any salaried office of the society. In regard thereof, no activity being c…

JAIBHARAT MANDAL RAMLILA AND DHARAMSHALA SOCIETY,HISAR vs. ITO (EXEMPTION), ROHTAK

ITA 5274/DEL/2019[2009-10]Status: DisposedITAT Delhi23 Mar 2022AY 2009-10

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…ve been held to be charitable because there is no profit motive. Reliance in this regard is placed on the decision of the hon’ble Delhi High Court in the case of Institute of Chartered Accountants of India v. Director General of Income-tax (Exemptions) [2013] 358 ITR 91 (Delhi). The objects of the society provide clearly that income of the society if any is to be used for the objects of the society and no portion thereof is to be transferred to the members directly or indirectly. Further the members are also barred from being appointed to any salaried office of the society. In regard thereof, no activity being c…

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