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

178 ITR 359High Court1989#4307 most cited

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.

27

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2021 to 2025.

Also referred to as

Girijan Co-operative Corporation Ltd v. CIT · Section 2(15) · charitable purpose · general public utility · section of public · sizable number of members of public · benefit of public at large

Sections most often in play

Section 12AASection 13(1)(c)Section 13(8)Section 2(15)

Issues it is cited on

section 2(15)registration under section 12asection 12aasection 12asection 12section 11section 13personindiadocumentinterest

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

Lucknow Development Authority, Lucknow vs. DCIT (E), Lucknow

In the result, all the appeals of the assessee are partly allowed

ITA 656/LKW/2019[2012-13]Status: DisposedITAT Lucknow05 Apr 2022AY 2012-13

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

Section 11Section 12Section 13(1)(c)Section 13(3)Section 143(3)Section 147Section 154Section 2(15)Section 40

…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 b…

Lucknow Development Authority, Lucknow vs. DCIT (E), Lucknow

In the result, all the appeals are partly allowed

ITA 439/LKW/2019[2016-17]Status: DisposedITAT Lucknow10 Mar 2022AY 2016-17

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 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 b…

Lucknow Development Authority, Lucknow vs. ACIT (E), Lucknow

In the result, all the appeals are partly allowed

ITA 186/LKW/2019[2013-14]Status: DisposedITAT Lucknow10 Mar 2022AY 2013-14

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 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 b…

Lucknow Development Authority, Lucknow vs. ACIT (E), Lucknow

In the result, all the appeals are partly allowed

ITA 185/LKW/2019[2013-14]Status: DisposedITAT Lucknow10 Mar 2022AY 2013-14

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 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 b…

Lucknow Evelopment Authority, Lucknow vs. I.T.O., Lucknow

In the result, all the appeals are partly allowed

ITA 164/LKW/2019[2015-16]Status: DisposedITAT Lucknow10 Mar 2022AY 2015-16

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 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 b…

Lucknow Development Authority, Lucknow vs. Assistant Commissioner of Income Tax (Exemption), Lucknow

In the result, all the appeals are partly allowed

ITA 163/LKW/2019[2014-15]Status: DisposedITAT Lucknow10 Mar 2022AY 2014-15

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

Section 11Section 11rSection 12Section 12ASection 13(1)(c)Section 13(3)Section 143(3)Section 147Section 148Section 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 b…

Agra Development Authority, Agra vs. DCIT., Circle-1, Agra

The appeals of the assessee are allowed and the appeal of the revenue is dismissed

ITA 216/AGR/2016[2011-12]Status: DisposedITAT Agra17 May 2021AY 2011-12
Section 124Section 142Section 153

…he above case was again followed by the Hon'ble Supreme Court in the case of Thiagarajar Charities v. Addl. Commissiner of Income-tax & another 225 ITR 1010 and A.P. High Court in the case of Girijan Co-operative Corporation Ltd. v. Commissioner of Income-tax 178 ITR 359. (3.10) Recently, the Hon'ble Supreme Court in the case of Queen's Educational Society v. CIT [2015] 372 ITR 699 had reversed the decision of the UttarkhandHigh Court, which held that when there is heavy profit the educational institution is intended for profit and therefore, exemption was denied. The very fact that the profit was large made the…