New Noble Educational Society v. Chief Commissioner of Income Tax

448 ITR 594Supreme Court of India2022#2300 most cited

What is New Noble Educational Society v. Chief Commissioner of Income Tax authority for?

An institution qualifies as an 'educational institution' for tax exemption, including under Section 10(23C)(iiiab), only if it imparts structured, formal education, distinguishing it from general public utility activities under Section 2(15).

50

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2026.

Also referred to as

New Noble Educational Society v. CIT · 448 ITR 594 · Supreme Court · definition of education · structured formal education · Section 10(23C)(iiiab) · Section 2(15) · charitable purpose · educational institution exemption · Section 12A registration · general public utility

Sections most often in play

Section 11Section 12ASection 153ASection 153DSection 2(15)Section 12ABSection 143(3)Section 148
Read the full judgment

Issues it is cited on

section 274(2)section 243section 245hacasus omissussection 245csettlement applicationsection 245d(4)section 153(4)section 135asection 144basection 10(23)section 245d

Judgments citing New Noble Educational Society v. Chief Commissioner of Income Tax

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 38/ALLD/2019[2011-12]Status: DisposedITAT Allahabad30 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 37/ALLD/2019[2010-11]Status: DisposedITAT Allahabad30 Sept 2025AY 2010-11

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 36/ALLD/2019[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 35/ALLD/2019[2008-09]Status: DisposedITAT Allahabad30 Sept 2025AY 2008-09

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Vandana Bansal L/H of Late Dr. Ashwani Kumar Bansal, Allahabad vs. ACIT, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 34/ALLD/2019[2007-08]Status: DisposedITAT Allahabad30 Sept 2025AY 2007-08

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Minto Developers Pvt. Ltd., Allahabad vs. Assistant Commissioner of Income Tax, Central Circle, Allahabad

In the result, the appeals and Cross Objections filed by the assessees are allowed and the appeals of the Revenue are dismissed

ITA 337/ALLD/2018[2009-10]Status: DisposedITAT Allahabad30 Sept 2025AY 2009-10

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

…kumchand Mills Ltd. vs CIT and 53 ITR 225 (SC) CIT vs. Kanpur Coal Syndicate; for the proposition that ITAT has power to remand/remit the matter back to the authorities below in appropriate cases. They further placed reliance on the case laws in the cases of 448 ITR 594 (SC) New Noble Educational Society vs. CCIT; 262 ITR 278 (SC) Pandian Chemicals Ltd. vs. CIT and 100 ITR 698 (SC) Raja Jagdambika Pratap Narain Singh vs. CBDT for the proposition that where a word used in the statute is unambiguous/unequivocal and capable of only one meaning, the legislation has to be given effect of the word in its own terms and…

Shreeji Janseva Khandi Gramodhyog Sangh, Ahmedabad vs. The CIT(Exemption), Ahmedabad

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

ITA 92/AHD/2025[NA]Status: HeardITAT Ahmedabad26 Aug 2025

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Alpesh Shah, C.AFor Respondent: Shri R P Rastogi, CIT DR
Section 12A

…the objects of the trust and (iii) whether other laws material for achieving the objects were complied with. 4. Placing reliance on the judgments of the Hon’ble Supreme Court in CIT v. Dawoodi Bohra Jamat (364 ITR 31) and New Noble Educational Society v. CIT (448 ITR 594), the CIT(E) rejected the Shreeji Janseva Khandi Gramodyog Sangh vs. CIT(E) Asst.Year –N.A. - 3– application in Form 10AB and also cancelled the provisional registration. 5. Aggrieved by the order of CIT(E), the assessee is in appeal before us raising following grounds of appeal: 1. The learned CIT (Exmp) has erred in law and on facts in reject…

Siddartha Educational Academy, Karimnagar vs. CIT (Exemption), Hyderabad

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

ITA 456/HYD/2025[2025-26]Status: DisposedITAT Hyderabad17 Jun 2025AY 2025-26

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Ramesh Babu KilaruFor Respondent: Sri B Bala Krishna, CIT-DR
Section 12A

…1 ITA.No.456/Hyd./2025 IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “A” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G, ACCOUNTANT MEMBER ITA.No.456/Hyd./2025 Assessment Year 2025-2026 Siddartha Educational The Commissioner of Academy, Karimnagar. [vs. Income Tax (Exemption), PIN – 505001 PAN AADTS2169K Hyderabad. (Appellant) (Respondent) For Assessee : CA Ramesh Babu Kilaru For Revenue : Sri B Bala Krishna, CIT-DR Date of Hearing : 16.06.2025 Date of Pronouncement : 17.06.2025 ORDER PER MANJUNATHA G. : This appeal has been filed by the Assessee Company against the order dated…

Haryana State Remote Sensing Application Centre, Hissar vs. DCIT (Exemptions), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 354/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh26 May 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Rohit Sharma, CIT, DR (Virtual Mode)
Section 10Section 142(1)Section 143(3)Section 263

…supported the revisionary order, arguing that the AO did not conduct proper inquiry into the educational nature of the assessee’s activities or its funding status. He relied on the judgment of the Hon’ble Supreme Court in New Noble Educational Society [(2022) 448 ITR 594 (SC)] to argue that an institution must impart structured, formal education to qualify under Section 10(23C)(iiiab), and that the AO did not satisfactorily examine this aspect. 8. We have heard both sides and carefully examined the record. It is not in dispute that the AO considered the assessee’s activities in light of the provisions of Section…

Gujarat Council of Science City, Ahmedabad vs. The Dy.CIT, Circle-1(Exemp), Ahmedabad

In the result, appeal of the assessee is partly allowed for statistical purpose and the Stay Application filed by the assessee is dismissed

ITA 1822/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad19 Feb 2025AY 2018-19

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2018-19

Section 11Section 11(1)(d)Section 12ASection 143(1)Section 2(15)Section 250

…l for earlier years i.e. A.Y. 2013-14 to 2015-16 (ITA No.2405/Ahd/2017 dated 20.03.2023) and order in ITA No.273/Ahd/2022 for A.Y. 2016-17 dated 13.09.2023 that in view of the decision of Hon'ble Supreme Court in case of New Global Education Society vs. CCIT (448 ITR 594), the activities were not in nature of "education" but in the nature of "advancement of any other object of general public utility" (See para-12 and 18 of the order). However, the appellant continues to contend that the activities are in the nature of “education" ITA No.1822/Ahd/2024 & S.A. No.1/Ahd/2025 (Assessment Year: 2018-19) Gujarat Counci…

Rao Pahlad Singh Education Society, Haryana vs. CIT(E), Chandigarh

In the result, appeal of the Assessee is allowed

ITA 477/CHANDI/2023[2023-24]Status: DisposedITAT Chandigarh21 Oct 2024AY 2023-24

Bench: The Ld. Pcit, For Grant Of Approval. Alongwith The Application, The Assessee Filed A Copy

For Appellant: Shri Gautam Jain, Advocate and Shri Lalit Mohan, C.AFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 10Section 143(2)

…the provisions of Sections 11 and 10(23C)(vi) of the Act, and that it had, further correctly, been held that the funds of the society were not utilized for any purpose other than the object of the society. 30. Apropos ‘New Nobel Educational Society Vs. CCIT’, 448 ITR 594 (SC), on which, vehement reliance has been sought to be placed on behalf of the Department, the same aids the case of the assessee, rather than that of the Department. Therein, their Lordships have held that an Educational institution must, for the propose of Section 10(23C) of the Act, exist solely for educational activity and not for profit. Un…

Iti Education Committe, Bengaluru vs. Income Tax Officer, Ward-1, Bengaluru

In the result, the appeal filed by the assessee is allowed for the statistical purposes

ITA 563/BANG/2024[2014-15]Status: DisposedITAT Bangalore19 Aug 2024AY 2014-15

Bench: Shri George George K & Shri Waseem Ahmedassessment Year : 2014-15

For Appellant: Shri Shambu Sharma, C.AFor Respondent: Ms. Matta Padma, Addl. CIT (DR)
Section 10Section 11Section 12A

…ed by the AO and further made reliance on the judgment of Hon’ble . Page 4 of 8 Supreme Court in the case of Union of India vs Baba Banda Singh Bahadur Education Trust reported in 150 taxmann.com 40 and New Nobel Education Society vs. CIT reported in [2022] 448 ITR 594 (SC). It is pertinent to note that as per the revenue the surplus generated by the assessee for the year under consideration was to the tune of 34% whereas it was contended by the assessee that the surplus was only 29%. Furthermore, it was also contended by the assessee that the surplus of 29% was calculated after including the interest income of…

Commissioner of Income-Tax, Patiala vs. Young Scholars Educaiton Society, Barnala

ITA/21/2011HC Punjab & Haryana08 May 2024

Bench: This Court Under Section 260A Of The Income Tax Act, 1961 (Hereinafter To Be Referred As “The Act”) Against The Order Dated 16.07.2010 Passed By The Income Tax Appellate Tribunal, Chandigarh Bench-A, Chandigarh (Hereinafter To Be Referred As “The Itat”) In Ita No. 510/Chd/2010 - M/S Young Scholars Educational Society, Barnala Vs Cit, Patiala, Whereby The Order Dated 26.03.2010 Passed By The Commissioner Of Income Tax, Patiala (Hereinafter To Be Referred As “The Commissioner”) Was Quashed & The Varinder Singh 2024.05.13 10:09 I Attest To The Accuracy & Authencity Of This Order/Judgment

Section 12ASection 2(15)Section 260A

…ancellation of registration granted under Section 12A of the Act is required to be examined in law of the recent judgment of the Larger Bench of Hon’ble the Supreme Court in New Noble Educational Society vs Chief Commissioner of Income-Tax and another (2022) 448 ITR 594. After having considered the entire law with reference to Section 10 (23C)(vi) of the Act as well as Section 11 (4A) of the Act and the law as examined in Pinegrove and Queen’s Educational Society’s cases (supra), it reached to the following conclusion:- 76. The conclusions of this court are summarized as follows: (a) It is held that the require…

Ashwini Sahakari Rungnalaya & Research Center, Solapur vs. Commissioner of Income-Tax, (Exemptions), Pune

ITA 714/PUN/2018[N.A]Status: DisposedITAT Pune07 Mar 2024

Bench: Hon’Ble Shri S. S. Viswanethra Ravi & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 714/Pun/2018 Ashwini Sahakari Rugnalaya & Research Centre 7107/1, Plot No. 180, North Sadar Bazar, Solapur-413003. Pan: Aaaja0041K . . . . . . . अपीलार्थी / Appellant

For Appellant: Mr Pramod Shingte [‘Ld. AR’]For Respondent: Mr Keyur Patel [‘Ld. DR’]
Section 10Section 10(23)Section 11Section 12ASection 22Section 253(1)(c)

…ncellation passed by the Ld. CIT(E) in our considered view is perfectly well within law. To support this proposition the Ld. Mr Patel sought our attention to para 69-70 of Hon’ble Apex Court’s judgement in ‘New Noble Education Society Vs CCIT’ 290 Taxman 206 [448 ITR 594]. Per contra the Ld. AR displaced the Revenue’s contention stating in first place that, BPT/MPT also recognises society as public trust, then averred that no separate registration thereunder is pre-requisite for seeking registration under the Act in the light of decision rendered in ‘CIT Vs Gujarat Maritime Board’ reported in [2007] 295 ITR 561(S…

The Nehru Memorial Education Society, Kanhangad vs. ITO Exemptions, Kannur

In the result, the assessee’s appeal is allowed

ITA 159/COCH/2023[2013-14]Status: DisposedITAT Cochin07 Mar 2024AY 2013-14

Bench: Shri Sanjay Arora & Dr. S. Seethalakshmithe Nehru Memorial The Income Tax Officer Education Society (Exemptions), Kannur Lakshmi Nivas Vs. Kanhangad - 671315 Kasaragod [Pan:Aabtt0633M] (Appellant) (Respondent)

For Appellant: Shri P.M. Veeramani, CAFor Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 10Section 11(1)Section 11(1)(d)Section 12ASection 143(1)Section 143(1)(a)Section 154Section 2

…withdrew it’s application for approval u/s.10(23C)(vi), and which, as indeed sec.10(23C)(iiiad), requires the assessee to exists solely for the purposes of education, which aspect thus cannot be said to be satisfied (New Noble Education Society v. CCIT [2022] 448 ITR 594 (SC)). There is, however, nothing on record to show that the assessee was engaged in any other activity, or of it’s receipt being from any other. There is, further, no scope, again, for reference to material other than specified in sec.143(1)(a) for making an adjustment there-under. It is only under regular assessment that the said aspects, as in…

Patheya Kan Sansthan, Jaipur vs. Assistant Commissioner of Income Tax, Circle-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 583/JPR/2019[2010-11]Status: DisposedITAT Jaipur13 Feb 2024AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Anoop Singh,Addl.CIT
Section 11Section 12ASection 143(2)Section 143(3)Section 2Section 2(15)

…. Ld. CIT(A) confirmed the order of Ld. AO. 4. This is in continuation to our earlier Gist of Submissions dated 20/09/2021. 5. Recently following two judgments have been delivered by the Hon’ble Supreme Court: (i) New Noble Educational Society v. CIT [2022] 448 ITR 594 (SC) in respect of charitable activities in the nature of education (ii) ACIT v. Ahmedabad Urban Development Authority [2022] 449 ITR 1 (SC) (Copy Enclosed) in respect of charitable activities in the nature of Any Other Object of General Public Utility (GPU) 6. In terms of decision of the Hon’ble Supreme Court in the case of New Noble Educationa…

Durgapur Society of Management Science, Durgapur vs. ITO, Cir-2, Exempt, Kol., Kolkata

In the result, appeal of the assessee is allowed

ITA 498/KOL/2023[2018-19]Status: DisposedITAT Kolkata01 Dec 2023AY 2018-19

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 498/Kol/2023 Assessment Year: 2018-19 Durgapur Society Of Management Income Tax Officer, Circle-2, Science Vs Exempt, Kolkata Dr. Zakir Hussain Avenue Hudco More Bidhannager Durgapur - 713206 [Pan : Aaatd7804P] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Sunil Surana, A.R. Revenue By : Shri Abhijit Kundu, Cit, D/R सुनवाई क" तारीख/Date Of Hearing : 06/09/2023 घोषणा क" तारीख /Date Of Pronouncement: 01/12/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The Commissioner Of Income Tax (Exemption) (Hereinafter The “Ld. Cit(E)”) Dt. 21/03/2023, Passed U/S 263 Of The Income Tax Act, 1961 (“The Act”) For The Assessment Year 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal:- “1. For That The Ld Pcit Erred In Setting Aside The Order In The Light Of The Judgement Of The Hon'Ble Apex Court In The Case Of New Noble Educational Society Pronounced On 19Th Oct, 2022 When The Judgement Itself Clearly Stated That It Should Be Applied Prospectively & Therefore The Order Of The Pcit Should Be Quashed Since The Order Passed By The Ao Was Neither Erroneous Nor Prejudicial To The Interests Of Revenue. 2. For That The Ld Pcit Erred In Holding That The Rent Received From The Building Which Was Let Out Since Lying Idle For Some Period Constituted Income From Business When The Objects The Predominant Object Of The Society Was Providing Education & 2

For Appellant: Shri Sunil Surana, A.RFor Respondent: Shri Abhijit Kundu, CIT, D/R
Section 10Section 11(5)Section 142(1)Section 143(3)Section 263

…the decision of the Hon’ble Jurisdictional High Court in the case of DIT(Exemption) vs. Sahu ]ain Trust [(2011) 243 CTR 131(Cal.). Reference was further made to the judgement of the Hon’ble Apex Court in the case of New Noble Educational Society V. Chief CIT 448 ITR 594 (SC), wherein the Hon’ble Court has held that since the present judgement has departed from the previous rulings regarding the meaning of the term ‘solely’, in order to avoid disruption, and to give time to institutions likely to be affected to make appropriate changes and adjustments, it would be in the larger interests of society that the prese…

National Institute of Bank Management, Mumbai vs. Assessing Officer, National Faceless Centre, Delhi

In the result, the appeal of the assessee is allowed with above direction

ITA 757/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Jul 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm National Institute Of Bank Assessing Officer, Management, National Faceless S-14, Pemino, Altamount Vs. Assessment Centre, Delhi Road, Mumbai-400 026 (Appellant) (Respondent) Pan No. Aaatnp0040P Dy. Commissioner Of Income Tax, (Exemption) 2(1) National Institute Of Bank Room No.608, Management, 6Th Floor S-14, Pemino, Altamount Vs. Mtnl Building, Road, Cumballa Hill, Mumbai-400 026 Mumbai-400 026

For Appellant: Shri S. AnanthanFor Respondent: Shri Suresh Gaikwad, DR
Section 10Section 10(23)(c)Section 11Section 12ASection 143(3)Section 144BSection 2

…of the Act with the assessee. We direct the learned Assessing Officer to examine the same if same is subsisting then the issue may be decided in case of the assessee by following the decision of the Hon'ble Supreme Court in case of New Noble education society 448 ITR 594. Accordingly Ground no 1 & 2 are allowed for statistical purposes. 09. With respect to the benefit under Section 11,12 of the Act, we direct the learned Assessing Officer to compute the income of the assessee under the provisions of Section 11, 12 of the Act. Accordingly, ground no.3, 4 of the appeal are allowed. 010. In the result, the appeal of…

Dy. Commissioner of Income Tax (Exemption)-2(1), Mumbai vs. National Institute of Bank Management, Mumbai

In the result, the appeal of the assessee is allowed with above direction

ITA 1192/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Jul 2023AY 2018-19

Bench: Shri Prashant Maharishi, Am & Shri Narender Kumar Choudhry, Jm National Institute Of Bank Assessing Officer, Management, National Faceless S-14, Pemino, Altamount Vs. Assessment Centre, Delhi Road, Mumbai-400 026 (Appellant) (Respondent) Pan No. Aaatnp0040P Dy. Commissioner Of Income Tax, (Exemption) 2(1) National Institute Of Bank Room No.608, Management, 6Th Floor S-14, Pemino, Altamount Vs. Mtnl Building, Road, Cumballa Hill, Mumbai-400 026 Mumbai-400 026

For Appellant: Shri S. AnanthanFor Respondent: Shri Suresh Gaikwad, DR
Section 10Section 10(23)(c)Section 11Section 12ASection 143(3)Section 144BSection 2

…of the Act with the assessee. We direct the learned Assessing Officer to examine the same if same is subsisting then the issue may be decided in case of the assessee by following the decision of the Hon'ble Supreme Court in case of New Noble education society 448 ITR 594. Accordingly Ground no 1 & 2 are allowed for statistical purposes. 09. With respect to the benefit under Section 11,12 of the Act, we direct the learned Assessing Officer to compute the income of the assessee under the provisions of Section 11, 12 of the Act. Accordingly, ground no.3, 4 of the appeal are allowed. 010. In the result, the appeal of…

Indian Institute of Banking and Finance ( Formerly Known As the Indian Institute of Bankers), Mumbai vs. CIT (Exemptions), Mumbai

In the result, all the appeals by the assessee are dismissed

ITA 875/MUM/2021[2019-21]Status: DisposedITAT Mumbai17 May 2023AY 2019-21

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Purushottam Tripuri
Section 10Section 10(22)Section 2(15)

…ty or other educational institution, and they must exist solely for educational purposes and not for the purposes of profit, are identical in both the sections. We find that recently in New Noble Educational Society vs Chief Commissioner of Income Tax, [2022] 448 ITR 594 (SC), the Hon‟ble Supreme Court while examining section 10(23C)(vi) of the Act considered all the previous decisions and came to the conclusion that a trust, university or other institution imparting education should necessarily have all its objects aimed at imparting or facilitating education, for the purpose of claiming the exemption under the…