Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (178 ITR 359)

Q: What is Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT authority for?

For an entity to satisfy the definition of 'charitable purpose' under Section 2(15), it is not necessary for its benefits to reach every individual; it is sufficient if a sizable section of the public benefits.

Q: How many judgments cite Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT?

27 judgments on BharatTax cite Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (178 ITR 359), spanning 2021 to 2025.

Q: Which sections of the Income Tax Act does Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT come up under?

It is most often cited in judgments turning on Section 12AA, Section 13(1)(c), Section 13(8), Section 2(15).

ICG-IISU ALUMNAE ASSOCIATION-BANDHAN,JAIPUR vs. CIT (EXEMPTION), JAIPUR, JAIPUR

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

ITA 923/JPR/2024[NA]Status: DisposedITAT Jaipur11 Sept 2025

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

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Ajey Malik, CIT-DR (Thru:V.C.)

Section 12ASection 13(1)Section 254

…ublic. It is well settled that for satisfying the requirements of Section 2(15), it is not necessary that the benefit should reach each and every poor person in the state or country. The court in the case of Girijan Co-operative Corporation Ltd vs. CIT [1989] 178 ITR 359(AP) held that it is sufficient if it reaches a sizable number of members of public. It is also pertinent to mention that the Coordinate Bench at Ahmedabad in the case of Parul University Alumni Association v. CIT (E) in ITA No. 70/Ahd/2024 has allowed the grant of 16 ICG-IISU ALUMNAE ASSOCIATION – BANDHAN VS CIT (EXEMPTION), JAIPUR registration u…

INDUS ALUMNI ASSOCIATION,AHMEDABAD vs. THE CIT(EXEMPTION), AHMEDABAD

In the result, the appeal filed by the Assessee is hereby allowed

ITA 916/AHD/2024[NA]Status: DisposedITAT Ahmedabad01 Nov 2024

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

Section 12ASection 2(15)

…public. It is well settled that for satisfying the requirements of Section 2(15), it is not necessary that the benefit should reach each and every poor person in the state or country. The court in the case of Girijan Co-operative Corporation Lid v. CIT [1989] 178 ITR 359(AP) held that it is sufficient if it reaches a sizable number of members of public Further it was submitted by the Ld Counsel for the assessee that in the case of CIT v. Indian Sugar Mills Association [1974] 97 ITR 486 (SC) it was held that "the expression object of general public utility' is not restricted to objects beneficial to the whole of m…

PARUL UNIVERSITY ALUMNI ASSOCIATION,VADODARA vs. THE COMMISSIONER OF INCOME TAX-EXEMPTION, AHMEDABAD

In the result, Ground No. 2 of the assessee’s appeal is allowed for statistical purposes

ITA 70/AHD/2024[-]Status: DisposedITAT Ahmedabad24 Apr 2024

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Samir Parikh, A.RFor Respondent: Shri Kamlesh Makwana, CIT-DR

Section 12ASection 12A(1)(ac)

…ublic. It is well settled that for satisfying the requirements of Section 2(15), it is not necessary that the benefit should reach each and every poor person in the state or country. The court in the case of Girijan Co-operative Corporation Ltd vs. CIT [1989] 178 ITR 359(AP) held that it is sufficient if it reaches a sizable number of members of public. Further it was submitted by the Ld. Counsel for the assessee that in the case of Parul University Alumni Association vs.CIT(E) Asst.Year –NA - 7– CIT vs. Indian Sugar Mills Association [1974] 97 ITR 486 (SC) it was held that "the expression object of general publ…

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 267/ALLD/2017[2014-15]Status: DisposedITAT Varanasi06 Jul 2022AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R

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

…ts charitable character merely because some profit arises from the activity [CIT v. Andhra Pradesh Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (1997) 225 ITR 1010 (SC), Girijan Co-operative Corporation Ltd v. CIT (1989) 178 ITR 359 (AP)]. In view of above, it is held that the receipt of money by way of sale consideration, sundry receipts, interest, rent etc. is arising out of sole purpose of growth and development of the areas and not to earn profit. 11. We further find that in the case of assessee itself in assessment year 2005-06, the Hon'ble Allahabad High Court in a bun…

VARANASI DEVELOPMENT AUTHORITY,VARANASEE vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTION), LUCKNOW

In the result appeal filed by assessee in ITA no

ITA 266/ALLD/2017[2013-14]Status: DisposedITAT Varanasi06 Jul 2022AY 2013-14

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R

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

…ts charitable character merely because some profit arises from the activity [CIT v. Andhra Pradesh Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (1997) 225 ITR 1010 (SC), Girijan Co-operative Corporation Ltd v. CIT (1989) 178 ITR 359 (AP)]. In view of above, it is held that the receipt of money by way of sale consideration, sundry receipts, interest, rent etc. is arising out of sole purpose of growth and development of the areas and not to earn profit. 11. We further find that in the case of assessee itself in assessment year 2005-06, the Hon'ble Allahabad High Court in a bun…

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTION), VARANASI

In the result appeal filed by assessee in ITA no

ITA 265/ALLD/2017[2012-13]Status: DisposedITAT Varanasi06 Jul 2022AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R

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

…ts charitable character merely because some profit arises from the activity [CIT v. Andhra Pradesh Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (1997) 225 ITR 1010 (SC), Girijan Co-operative Corporation Ltd v. CIT (1989) 178 ITR 359 (AP)]. In view of above, it is held that the receipt of money by way of sale consideration, sundry receipts, interest, rent etc. is arising out of sole purpose of growth and development of the areas and not to earn profit. 11. We further find that in the case of assessee itself in assessment year 2005-06, the Hon'ble Allahabad High Court in a bun…

M/S. VARANASI DEVELOPMENT AUTHORITY,VARANASI vs. ASSISTANT COMMISSIONER OF INCOME TAX , VARANASI

In the result appeal filed by assessee in ITA no

ITA 264/ALLD/2017[2011-12]Status: DisposedITAT Varanasi06 Jul 2022AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Ramit Kochar

For Appellant: ShriAshishBansal, AdvocateFor Respondent: ShriSunil Bajpai, CIT- D.R

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

…ts charitable character merely because some profit arises from the activity [CIT v. Andhra Pradesh Road Transport Corporation (1986) 159 ITR 1 (SC), Thiagrajan Charities v. Addl. CIT (1997) 225 ITR 1010 (SC), Girijan Co-operative Corporation Ltd v. CIT (1989) 178 ITR 359 (AP)]. In view of above, it is held that the receipt of money by way of sale consideration, sundry receipts, interest, rent etc. is arising out of sole purpose of growth and development of the areas and not to earn profit. 11. We further find that in the case of assessee itself in assessment year 2005-06, the Hon'ble Allahabad High Court in a bun…

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 701/LKW/2019[2017-18]Status: DisposedITAT Lucknow10 Jun 2022AY 2017-18