Queen’s Educational Society v. CIT

372 ITR 699Supreme Court of India2015#653 most cited

What is Queen’s Educational Society v. CIT authority for?

An educational institution that generates a surplus does not automatically lose its charitable status or cease to exist solely for educational purposes. This is true if the surplus is reinvested for its educational objectives, and the predominant object test determines if the institution's primary aim is education or profit.

152

judgments rely on this decision, according to BharatTax’s citation analysis of 370,744 Indian tax judgments — from 2011 to 2026.

Also referred to as

Queen's Educational Society v. CIT · Section 11 · Section 10(23C) · Section 2(15) · Section 12A · educational institution surplus · charitable purpose profit motive · predominant object test · income tax exemption

Also reported as

55 Taxmann.com 255

Sections most often in play

Section 11Section 12AASection 143(3)Section 142(1)Section 2(15)Section 10(23C)(v)Section 12ASection 139(4A)
Read the full judgment

Issues it is cited on

section 13(1)(c)(ii)section 10(22)section 158asection 13(3)section 10(23c)(vi)proviso to section 2(15)section 13(1)(c)section 13(1)interest free advancessection 10(23c)section 2(15)application of income

Judgments citing Queen’s Educational Society v. CIT

Roland Educational & Charitable Trust, Ganjam vs. Cheif CIT, Bhubaneswar

Appeals are allowed in above terms

ITA 265/CTK/2019[2007-08]Status: DisposedITAT Cuttack15 Feb 2021AY 2007-08

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S.K. TulsiyanFor Respondent: Shri M.K. Goutham, CIT-DR
Section 10

…neswar in having denied exemption u/s 10(23C)(vi) is against the settled law decided by the Hon 'ble Apex Court in the cases of American Hotel and Lodging Association Educational Institute vs. CBDT (2008) 301 ITR 86 (SC) and Queen's Educational Society (2015) 372 ITR 699 (SC) and the Hon'ble Tribunal by following the said decisions allowed exemption u/s 10(23C)(vi) to the assessee for AY 2014- 15. 6. That the appellant craves leave to amend, alter, modify, substitute, add to. abridge and/or rescind any or all of the above grounds.” 10. The Assessing Officer thereafter has finalized the assessment(s) on 26.03.201…

Roland Educational & Charitable Trust, Ganjam vs. Cheif CIT, Bhubaneswar

Appeals are allowed in above terms

ITA 264/CTK/2019[2005-06]Status: DisposedITAT Cuttack15 Feb 2021AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S.K. TulsiyanFor Respondent: Shri M.K. Goutham, CIT-DR
Section 10

…neswar in having denied exemption u/s 10(23C)(vi) is against the settled law decided by the Hon 'ble Apex Court in the cases of American Hotel and Lodging Association Educational Institute vs. CBDT (2008) 301 ITR 86 (SC) and Queen's Educational Society (2015) 372 ITR 699 (SC) and the Hon'ble Tribunal by following the said decisions allowed exemption u/s 10(23C)(vi) to the assessee for AY 2014- 15. 6. That the appellant craves leave to amend, alter, modify, substitute, add to. abridge and/or rescind any or all of the above grounds.” 10. The Assessing Officer thereafter has finalized the assessment(s) on 26.03.201…

Roland Educational & Charitable Trust, Ganjam vs. Cheif CIT, Bhubaneswar

Appeals are allowed in above terms

ITA 263/CTK/2019[2012-13]Status: DisposedITAT Cuttack15 Feb 2021AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S.K. TulsiyanFor Respondent: Shri M.K. Goutham, CIT-DR
Section 10

…neswar in having denied exemption u/s 10(23C)(vi) is against the settled law decided by the Hon 'ble Apex Court in the cases of American Hotel and Lodging Association Educational Institute vs. CBDT (2008) 301 ITR 86 (SC) and Queen's Educational Society (2015) 372 ITR 699 (SC) and the Hon'ble Tribunal by following the said decisions allowed exemption u/s 10(23C)(vi) to the assessee for AY 2014- 15. 6. That the appellant craves leave to amend, alter, modify, substitute, add to. abridge and/or rescind any or all of the above grounds.” 10. The Assessing Officer thereafter has finalized the assessment(s) on 26.03.201…

Roland Educational & Charitable Trust, Ganjam vs. Cheif CIT, Bhubaneswar

Appeals are allowed in above terms

ITA 262/CTK/2019[2011-12]Status: DisposedITAT Cuttack15 Feb 2021AY 2011-12

Bench: Shri Satbeer Singh Godara & Shri Laxmi Prasad Sahu

For Appellant: Shri S.K. TulsiyanFor Respondent: Shri M.K. Goutham, CIT-DR
Section 10

…neswar in having denied exemption u/s 10(23C)(vi) is against the settled law decided by the Hon 'ble Apex Court in the cases of American Hotel and Lodging Association Educational Institute vs. CBDT (2008) 301 ITR 86 (SC) and Queen's Educational Society (2015) 372 ITR 699 (SC) and the Hon'ble Tribunal by following the said decisions allowed exemption u/s 10(23C)(vi) to the assessee for AY 2014- 15. 6. That the appellant craves leave to amend, alter, modify, substitute, add to. abridge and/or rescind any or all of the above grounds.” 10. The Assessing Officer thereafter has finalized the assessment(s) on 26.03.201…

ITO (E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1131/DEL/2016[2011-12]Status: DisposedITAT Delhi24 Dec 2020AY 2011-12

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI AMIT SHUKLA, JUDICIAL MEMBER (Through Video Conferencing) Assessment Year: 2007-08 IILM Foundation, v. Asst. Director of Income Tax Rai School Complex, (Exemption), 3, Lodhi Institutional Area, Trust Circle-II, Laxmi Nagar, Lodhi Road, New Delhi. New Delhi. TAN/PAN: AAATR8309M (Appellant) (Respondent) ITAs No. 2675/DEL/2013, 2871/DEL/2014, 2872/DEL/2014 & 1131/DEL/2016 Assessment Years: 2008-09, 2009-10, 2010-11 & 2011-12 Asst. Director of Income Tax v. IILM Foundation, (Exemption), Rai School Complex…

ADIT(E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2872/DEL/2014[2010-11]Status: DisposedITAT Delhi24 Dec 2020AY 2010-11

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI AMIT SHUKLA, JUDICIAL MEMBER (Through Video Conferencing) Assessment Year: 2007-08 IILM Foundation, v. Asst. Director of Income Tax Rai School Complex, (Exemption), 3, Lodhi Institutional Area, Trust Circle-II, Laxmi Nagar, Lodhi Road, New Delhi. New Delhi. TAN/PAN: AAATR8309M (Appellant) (Respondent) ITAs No. 2675/DEL/2013, 2871/DEL/2014, 2872/DEL/2014 & 1131/DEL/2016 Assessment Years: 2008-09, 2009-10, 2010-11 & 2011-12 Asst. Director of Income Tax v. IILM Foundation, (Exemption), Rai School Complex…

ADIT(E), New Delhi vs. M/S. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2871/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Dec 2020AY 2009-10

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI AMIT SHUKLA, JUDICIAL MEMBER (Through Video Conferencing) Assessment Year: 2007-08 IILM Foundation, v. Asst. Director of Income Tax Rai School Complex, (Exemption), 3, Lodhi Institutional Area, Trust Circle-II, Laxmi Nagar, Lodhi Road, New Delhi. New Delhi. TAN/PAN: AAATR8309M (Appellant) (Respondent) ITAs No. 2675/DEL/2013, 2871/DEL/2014, 2872/DEL/2014 & 1131/DEL/2016 Assessment Years: 2008-09, 2009-10, 2010-11 & 2011-12 Asst. Director of Income Tax v. IILM Foundation, (Exemption), Rai School Complex…

ADIT (E), New Delhi vs. Iilm Foundation, New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2675/DEL/2013[2008-09]Status: DisposedITAT Delhi24 Dec 2020AY 2008-09

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI AMIT SHUKLA, JUDICIAL MEMBER (Through Video Conferencing) Assessment Year: 2007-08 IILM Foundation, v. Asst. Director of Income Tax Rai School Complex, (Exemption), 3, Lodhi Institutional Area, Trust Circle-II, Laxmi Nagar, Lodhi Road, New Delhi. New Delhi. TAN/PAN: AAATR8309M (Appellant) (Respondent) ITAs No. 2675/DEL/2013, 2871/DEL/2014, 2872/DEL/2014 & 1131/DEL/2016 Assessment Years: 2008-09, 2009-10, 2010-11 & 2011-12 Asst. Director of Income Tax v. IILM Foundation, (Exemption), Rai School Complex…

Iilm Foundaion, New Delhi vs. ADIT (Exemption), New Delhi

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1142/DEL/2011[2007-08]Status: DisposedITAT Delhi24 Dec 2020AY 2007-08

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “C” NEW DELHI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI AMIT SHUKLA, JUDICIAL MEMBER (Through Video Conferencing) Assessment Year: 2007-08 IILM Foundation, v. Asst. Director of Income Tax Rai School Complex, (Exemption), 3, Lodhi Institutional Area, Trust Circle-II, Laxmi Nagar, Lodhi Road, New Delhi. New Delhi. TAN/PAN: AAATR8309M (Appellant) (Respondent) ITAs No. 2675/DEL/2013, 2871/DEL/2014, 2872/DEL/2014 & 1131/DEL/2016 Assessment Years: 2008-09, 2009-10, 2010-11 & 2011-12 Asst. Director of Income Tax v. IILM Foundation, (Exemption), Rai School Complex…

M/S. Rajasthan Cricket Association, Jaipur vs. Add.CIT. Range-2, Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the ground of appeal so taken by the assessee society is thus allowed

ITA 284/JPR/2020[2011-12]Status: DisposedITAT Jaipur25 Nov 2020AY 2011-12
For Appellant: Shri Shyam Lal Agarwal (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT) &

…Vs. Rajasthan Cricket Association. provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Seth Ramjidas Modi Vidhya Niketan Society, Kota vs. CIT(Exemptio), Jaipur

ITA 197/JPR/2020[2019-20]Status: DisposedITAT Jaipur10 Sept 2020AY 2019-20
For Appellant: Shri Mahendra Gargieya (Adv) &For Respondent: Shri B.K. Gupta (CIT-DR)
Section 10Section 11(5)Section 12A

…ety- trust which is running educational institutions on the mere ground that the method of admission of students followed by it has been held to be illegal by the court." 14. The Hon’ble Supreme Court in the case of Queen’s Educational Society vs. CIT (2015) 372 ITR 699 (SC), held that Exemption under ss. 10(23C)(iiiad) and 10(23C)(vi)—Educational institution—Profit motive— Where an educational institution carries on the activity of education primarily for educating persons, the fact that it makes a surplus does not lead to the conclusion that it has ceased to exist solely for educational purposes and has become…

M/S. Arvinth Charitable Trust, Namakkal vs. CIT, Salem

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

ITA 267/CHNY/2010[-]Status: DisposedITAT Chennai24 Feb 2020

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

For Respondent: Shri. Abani Kanta Nayak, CIT
Section 12ASection 2(15)

…is a question of fact which will be decided based on the nature, scope, extent and frequency of the activity’’. Further, we note that reliance placed by the ld. CIT in the case of Queens Educational Society (supra) was over ruled by Hon'ble Supreme Court in 372 ITR 699. In the light of this factual position, we are of the considered opinion that the proviso to Section 2(15) of the Act is not applicable to trust. In the circumstances, we direct the ld. CIT to grant registration u/s.12AA of the Act. In the result, the appeal filed by the assessee is allowed. 7. Order pronounced on 24th day of February, 2020, a…

Trident Academy of Creative Technology, Bhubaneswar vs. CIT(Exemptions), Hyderabad

In the result, appeal of the assessee is dismissed

ITA 177/CTK/2018[2017-08]Status: DisposedITAT Cuttack17 Feb 2020AY 2017-08

Bench: Shri Chandra Mohan Garg & Laxmi Prasad Sahutrident Academy Of Creative Vs. Cit (Exemptions) Hyderabad Technology, Plot No.F2/B1, Chandaka Industrial Estate, Chandrasekharpur, Bhubaneswar. Pan/Gir No.Aabtt 0273 H (Appellant) .. ( Respondent)

For Appellant: Shri Dillip Mohanty, ARFor Respondent: Shri M.K. Goutam, CIT DR
Section 12ASection 80GSection 80G(5)Section 80G(5)(vi)

…That the findings of the Ld CIT(E) that the trust is existing only for profit referring to the surplus generated during past years is opposed to the judicial dictum including the landmark judgment of the Apex Court in Queens Educational Society vs CIT (2015) 372 ITR 699 (SC), judgement of the Hon’ble Allahabad High Court in CIT v. Dr V.S.Educational Foundation in ITA 345/2010 and that of Gujarat High Court in the case of N N Desai Charitable Trust v. CIT 246 ITR 452. 6. That the Ld. CIT(E) failed to appreciate the fact that Section 80G does not contemplate different yardsticks or different parameters to be appli…

Handicraft Development Association, Moradabad vs. CIT (Exemptions), Lucknow

Appeal of the assessee is dismissed

ITA 577/DEL/2016[]Status: DisposedITAT Delhi09 Jan 2020

Bench: Ms Suchitra Kamble & Shri Prashant Maharishii.T.A. No. 577/Del/2016 (A.Y - N.A.) Handicraft Development Vs Cit(Exemption), Association, 5, Ashok Marg, H-48, Behind Sai Mandir, Lucknow - 226001 Ram Ganga Vihar, Phase – I, Kanth Road, Moradabad -244001 (Pan : Aabah 1979 D) (Appellant) (Respondent) Appellant By -None- Respondent By Shri J. K. Mishra, Cit-D.R. Date Of Hearing 07.01.2020 Date Of Pronouncement 09.01.2020

Section 12A

…s of the case and in the Law the appellant’s objectives being charitable in nature is clearly entitled for seeking registration u/s 12A & appellant’s claim is supported from the decision of Supreme Court in the case of Queens Educational Society Vs CIT (2015) 372 ITR 699 (SC) & other decisions. That the appellant craves leave to Add to and / or Amend, modify or withdraw the grounds outlined above before or at the time of hearing of the appeal.” 3. The applicant society has filed an application for registration u/s 12A(a) of the Income Tax Act, 1961 on 14.05.2015 with the Commissioner of Income Tax (Exemptions), L…

Shri Bhanwar Lal Khichi, Ajmer vs. Income Tax Officer, Ward-2-3, Ajmer

In the result, the appeal of the assessee is allowed

ITA 1201/JPR/2018[2013-14]Status: DisposedITAT Jaipur06 Jan 2020AY 2013-14
For Appellant: Shri S. R. Sharma (C.A.) &For Respondent: Shri B.K. Gupta (CIT) a
Section 10Section 22

…parting education and its existence is not for profit only, it is entitled for exemption under Section 10(23C)(vi). Reference in this regard may be made to the judgment of the Hon’ble Supreme Court in the case of Queen’s Educational Society v. CIT reported in 372 ITR 699 (SC). wherein it was held as under: “24. …The Income Tax Act, 1961 does not condition the grant of an exemption under Section 10(23C) on the requirement that a college must maintain the status quo, as it were, in regard to its knowledge based infrastructure. Nor for that matter is an educational institution prohibited from upgrading its infrastru…

Income Tax Officer (Exemption), Ward-1, Jaipur vs. M/S Rajasthan Cricekt Association, Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the ground of appeal so taken by the assessee society is thus allowed

ITA 1356/JPR/2018[2011-12]Status: DisposedITAT Jaipur09 Dec 2019AY 2011-12
For Appellant: Shri Shyam Lal Agarwal (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT) &

…Vs. Rajasthan Cricket Association. provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Income Tax Officer (Exemption), Ward-1, Jaipur vs. Rajasthan Cricket Association, Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the ground of appeal so taken by the assessee society is thus allowed

ITA 1355/JPR/2018[2010-11]Status: DisposedITAT Jaipur09 Dec 2019AY 2010-11
For Appellant: Shri Shyam Lal Agarwal (CA) &For Respondent: Smt. Rooni Paul (Addl.CIT) &

…Vs. Rajasthan Cricket Association. provisions of section 13(1), the assessee society is not held eligible for exemption under section 11 of the Act. 15. Here, we refer to the decision of Hon'ble Supreme Court in case of Queen's Education Society v. CIT [2015] 372 ITR 699/231 Taxman 286/55 taxmann.com 255 where relevant principles of law have been laid down to determine whether an educational institution exists solely for educational purposes and not for profit. In that case, the provisions of section 10(23C)(iiiad) of the Act were under consideration of Hon'ble Supreme Court . The Revenue therein has argued that…

Gujarat Safety Council, Vadodara vs. The Income Tax Officer, Exemption Ward, Vadodara

In the result, Ground No.1 of the assessee’s appeal is allowed

ITA 485/AHD/2018[2012-13]Status: DisposedITAT Ahmedabad29 Nov 2019AY 2012-13

Bench: Shri Pradip Kumar Kedia & Shri Mahavir Prasad

For Appellant: Parin Shah, A.Rs
Section 1Section 11Section 2(15)

…d. 11.3 The courts have stated that if the activities are being carried on as part of charitable object, it cannot be said to be in the nature of trade, commerce or business. The Hon’ble Supreme Court in the case of Queen’s Educational Society vs. CIT [2015] 372 ITR 699 (SC) has held that a surplus arising from activities would not necessarily mean that institution is being carried on ‘for profit’. The Hon’ble Gujarat High Court in the case of DIT(Exemption) vs. Gujarat Cricket Association Tax Appeal No. 123 of 2014 judgment dated 27.09.2019 inter alia observed that the profits, if any, ploughed back into the ve…

ITO (E), New Delhi vs. M/S. Society Fo Participatory Research in Asia, New Delhi

In the result, appeal of the Revenue is dismissed

ITA 6165/DEL/2016[2012-13]Status: DisposedITAT Delhi05 Nov 2019AY 2012-13

Bench: Shri Amit Shukla & Shri O.P.Meena

Section 10(22)Section 11Section 12ASection 2(15)Section 80G

…-2(2), New Delhi V. Society for Participatory Research in Asia/ITA No.6165/DEL/2016 for A.Y. 2012-13 Page 8 of 9 any member of the Assessee society.” 7 As regards the basis of surplus, the Hon’ble Apex Court in the case of Queen’s Educational Society v. CIT 372 ITR 699 has referred to the judgment in the case of American Hotel & Lodging Association, Educational Institute v. CBDT 301 ITR 86 (SC) and noted as under: “11. Thus, the law common to Section 10(23C)(iiiad) and (vi) may be summed up as foll0ws: (1) Where an educational institution carries on the activity of education primarily for educating persons, th…

Devki Devi Foundation, New Delhi vs. DIT (Exemptions), New Delhi

ITA 1027/DEL/2012[]Status: DisposedITAT Delhi22 Oct 2019

Bench: Shri R.K. Panda & Ms Suchitra Kambleassessment Year: -- Devki Devi Foundation, Vs Dit (Exemptions), Plot No.15, 3Rd Floor, 2, Press Enclave Road, Saket, Aayakar Bhawan, New Delhi. Laxmi Nagar District Centre, New Delhi. Pan: Aaatd5283G (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate, Shri Gaurav Jain, Advocate & Shri Deepesh Jain, Ca Revenue By : Ms Nidhi Srivastava, Cit, Dr Date Of Hearing : 27.08.2019 Date Of Pronouncement : 22.10.2019 Order Per R.K. Panda, Am: The Appeal Filed By The Assessee Is Directed Against The Order Dated 28.12.2011 Of The Dit (Exemptions), Delhi Withdrawing Registration Granted Earlier U/S 12A Of The It Act Since Inception.

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Ms Nidhi Srivastava, CIT, DR
Section 12A

…ntitled to claim registration/approval u/s 12A of the Act. For the above proposition, the ld. counsel for the assessee relied on the following decisions:- i) CIT vs. Surat Art Silk Cloth Manufacturers, 121 ITR 1 (SC); ii) Queen’s Educational Society vs. CIT, 372 ITR 699 (SC); iii) CIT vs. Pulikkal Medical Foundation Pvt. Ltd., 210 ITR 299 (Ker); iv) Breach Candy Hospital Trust vs. CCIT, 322 ITR 246 (Bom); v) CIT vs. Bar Council of Maharashtra, 130 ITR 28 (SC); 28 vi) CIT vs. Andhra Pradesh State Road Transport Corporation: 159 ITR 1 (SC) vii) Victoria Technical Institute vs. CIT: 188 ITR 57 (SC) viii) Aditanar…