Sole Trustee, Loka Shikshana Trust v. CIT

101 ITR 234Supreme Court of India1975#239 most cited

What is Sole Trustee, Loka Shikshana Trust v. CIT authority for?

This case defines 'education' under Section 2(15) of the Income Tax Act as systematic instruction, schooling, or training given to the young for preparation for the work of life. It clarifies that 'education' in this context has a narrow meaning, not extending to every acquisition of further knowledge.

323

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2012 to 2026.

Also referred to as

Sole Trustee Loka Shikshana Trust v CIT · 101 ITR 234 · definition of education · section 2(15) education · scope of education · charitable purpose · section 11 exemption · systematic instruction · schooling · training · narrow meaning of education

Sections most often in play

Section 2(15)Section 11Section 12AASection 80GSection 12ASection 12Section 11(1)(a)Section 12AB
Read the full judgment

Issues it is cited on

section 52(2)section 10(22)advancement of general public utilitysection 52proviso to section 2(15)section 2(15)section 10(23c)(vi)section 10(23c)section 11(1)(a)section 11(1)section 12aaregistration under section 12a

Judgments citing Sole Trustee, Loka Shikshana Trust v. CIT

Periyar Public Press Trust, Chennai vs. JCIT (OSD) (Exemptions) II, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 771/CHNY/2018[2013-14]Status: DisposedITAT Chennai26 Aug 2022AY 2013-14

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 768, 769, 770 & 771/Chny/2018 िनधा"रण वष"/Assessment Years:2009-10, 2010-11, 2012-13 & 2013-14 Periyar Public Press Trust, The Joint Commissioner Of Vs. “Periyar Thidal”, 50, Income Tax (Sd), [Exemptions] Ii, Evk Sampath Salai No. 121, Nungambakkam High Road, Vepery, Chennai 600 007. Chennai 600 034. [Pan:Aaatp0542J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.08.2022 घोषणा की तारीख /Date Of Pronouncement : 26.08.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 10.01.2018 Relevant To The Assessment Years 2009-10, 2010-11, 2012-13 & 2013-14. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity. The Assessee Has Raised The Following Common Grounds:

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…st registered under section 12AA of the Act and also a fact that these magazines are subscribed by the followers of Periyar's ideology and principle. By relying upon the judgement of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust (101 ITR 234)(SC) with regard to the term 'education' as used in section 2(15) of the Act, the ld. CIT(A) was of the opinion that the activity undertaken by the assessee cannot be considered as education for income tax purposes. Moreover, by considering the provisos inserted below section 2(15) with effect from 01.04.2009 (as amended by the Finance Act, 2010,…

Periyar Public Press Trust, Chennai vs. JCIT (OSD) (Exemptions) II, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 770/CHNY/2018[2012-13]Status: DisposedITAT Chennai26 Aug 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 768, 769, 770 & 771/Chny/2018 िनधा"रण वष"/Assessment Years:2009-10, 2010-11, 2012-13 & 2013-14 Periyar Public Press Trust, The Joint Commissioner Of Vs. “Periyar Thidal”, 50, Income Tax (Sd), [Exemptions] Ii, Evk Sampath Salai No. 121, Nungambakkam High Road, Vepery, Chennai 600 007. Chennai 600 034. [Pan:Aaatp0542J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.08.2022 घोषणा की तारीख /Date Of Pronouncement : 26.08.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 10.01.2018 Relevant To The Assessment Years 2009-10, 2010-11, 2012-13 & 2013-14. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity. The Assessee Has Raised The Following Common Grounds:

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…st registered under section 12AA of the Act and also a fact that these magazines are subscribed by the followers of Periyar's ideology and principle. By relying upon the judgement of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust (101 ITR 234)(SC) with regard to the term 'education' as used in section 2(15) of the Act, the ld. CIT(A) was of the opinion that the activity undertaken by the assessee cannot be considered as education for income tax purposes. Moreover, by considering the provisos inserted below section 2(15) with effect from 01.04.2009 (as amended by the Finance Act, 2010,…

Periyar Public Press Trust, Chennai vs. JCIT (OSD) (Exemptions) II, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 769/CHNY/2018[2010-11]Status: DisposedITAT Chennai26 Aug 2022AY 2010-11

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 768, 769, 770 & 771/Chny/2018 िनधा"रण वष"/Assessment Years:2009-10, 2010-11, 2012-13 & 2013-14 Periyar Public Press Trust, The Joint Commissioner Of Vs. “Periyar Thidal”, 50, Income Tax (Sd), [Exemptions] Ii, Evk Sampath Salai No. 121, Nungambakkam High Road, Vepery, Chennai 600 007. Chennai 600 034. [Pan:Aaatp0542J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.08.2022 घोषणा की तारीख /Date Of Pronouncement : 26.08.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 10.01.2018 Relevant To The Assessment Years 2009-10, 2010-11, 2012-13 & 2013-14. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity. The Assessee Has Raised The Following Common Grounds:

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…st registered under section 12AA of the Act and also a fact that these magazines are subscribed by the followers of Periyar's ideology and principle. By relying upon the judgement of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust (101 ITR 234)(SC) with regard to the term 'education' as used in section 2(15) of the Act, the ld. CIT(A) was of the opinion that the activity undertaken by the assessee cannot be considered as education for income tax purposes. Moreover, by considering the provisos inserted below section 2(15) with effect from 01.04.2009 (as amended by the Finance Act, 2010,…

Periyar Public Press Trust, Chennai vs. JCIT (OSD) (Exemptions) II, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 768/CHNY/2018[2009-10]Status: DisposedITAT Chennai26 Aug 2022AY 2009-10

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 768, 769, 770 & 771/Chny/2018 िनधा"रण वष"/Assessment Years:2009-10, 2010-11, 2012-13 & 2013-14 Periyar Public Press Trust, The Joint Commissioner Of Vs. “Periyar Thidal”, 50, Income Tax (Sd), [Exemptions] Ii, Evk Sampath Salai No. 121, Nungambakkam High Road, Vepery, Chennai 600 007. Chennai 600 034. [Pan:Aaatp0542J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.08.2022 घोषणा की तारीख /Date Of Pronouncement : 26.08.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai Dated 10.01.2018 Relevant To The Assessment Years 2009-10, 2010-11, 2012-13 & 2013-14. Since The Facts Are Identical & Common Issue Has Been Raised, All The Appeals Were Heard Together & Being Disposed Of By This Common Order For The Sake Of Brevity. The Assessee Has Raised The Following Common Grounds:

For Appellant: Shri I. Dinesh, AdvocateFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

…st registered under section 12AA of the Act and also a fact that these magazines are subscribed by the followers of Periyar's ideology and principle. By relying upon the judgement of the Hon'ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust (101 ITR 234)(SC) with regard to the term 'education' as used in section 2(15) of the Act, the ld. CIT(A) was of the opinion that the activity undertaken by the assessee cannot be considered as education for income tax purposes. Moreover, by considering the provisos inserted below section 2(15) with effect from 01.04.2009 (as amended by the Finance Act, 2010,…

DCIT (E)-1(1), Mumbai vs. B P Marine Academy, Navi Mumbai

In the result, the appeal filed by the revenue is dismissed

ITA 963/MUM/2019[2014-15]Status: DisposedITAT Mumbai13 Jul 2022AY 2014-15
Section 11Section 12ASection 2(15)

…is exactly identical to the facts of the instant case before us. The Ld. CIT (A) has discussed the said judgment at length at para 4.4.1. of the impugned Appellate Order. We also find that the Ld. CIT (A) has also taken note of the case of Lokshikshan Trust [101 ITR 234(SC)] in which it was held Page that "the sense in which the word 'education' has been used in section 2(15) is the systematic instruction, schooling or training giving to the young in preparation for the walks of life. It also converts the old course of scholastic instruction which a person has received." Moreover, the Assessee also relied upon t…

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)

…rement of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. We may point out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as we shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. Assessment Year: 2011-12, 2012-13, 2013-14 and 2014-15. M/s. Varanasi Development Authority v. ACIT,Circle-3, Varanasi,U.P. 15. We must then proceed to consider what is the meaning of th…

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)

…rement of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. We may point out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as we shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. Assessment Year: 2011-12, 2012-13, 2013-14 and 2014-15. M/s. Varanasi Development Authority v. ACIT,Circle-3, Varanasi,U.P. 15. We must then proceed to consider what is the meaning of th…

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)

…rement of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. We may point out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as we shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. Assessment Year: 2011-12, 2012-13, 2013-14 and 2014-15. M/s. Varanasi Development Authority v. ACIT,Circle-3, Varanasi,U.P. 15. We must then proceed to consider what is the meaning of th…

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)

…rement of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. We may point out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as we shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. Assessment Year: 2011-12, 2012-13, 2013-14 and 2014-15. M/s. Varanasi Development Authority v. ACIT,Circle-3, Varanasi,U.P. 15. We must then proceed to consider what is the meaning of th…

Tata Chemicals Ltd, Mumbai vs. DCIT 2(2), Mumbai

In the result, appeal by the Revenue is dismissed

ITA 2692/MUM/2012[2005-06]Status: DisposedITAT Mumbai06 Jul 2022AY 2005-06

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/wFor Respondent: Smt. Somogyan Pal, CIT DR
Section 115JSection 14ASection 250Section 80Section 80HSection 80M

…erpretation of a statute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In fact there are at least three decisions of this Court, one in Loka Shikshana Trust v. Commissioner of Income-Tax [1975] 101 ITR 234 (SC) the other in Indian Chamber of Commerce v. Commissioner of Income-tax [1975] 101 ITR 796 (SC) and the third in Additional Commissioner of Income-tax v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR 1 (SC) where the speech made by the Finance Minister while introducing the exclusionary clause in Section 2 Clause (15) of the Ac…

DCIT 2(2), Mumbai vs. Tata Chemicals Ltd, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 2553/MUM/2012[2005-06]Status: DisposedITAT Mumbai06 Jul 2022AY 2005-06

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/wFor Respondent: Smt. Somogyan Pal, CIT DR
Section 115JSection 14ASection 250Section 80Section 80HSection 80M

…erpretation of a statute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In fact there are at least three decisions of this Court, one in Loka Shikshana Trust v. Commissioner of Income-Tax [1975] 101 ITR 234 (SC) the other in Indian Chamber of Commerce v. Commissioner of Income-tax [1975] 101 ITR 796 (SC) and the third in Additional Commissioner of Income-tax v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR 1 (SC) where the speech made by the Finance Minister while introducing the exclusionary clause in Section 2 Clause (15) of the Ac…

DCIT 2(2), Mumbai vs. Tata Chemicals Ltd, Mumbai

In the result, appeal by the Revenue is dismissed

ITA 2733/MUM/2011[2004-05]Status: DisposedITAT Mumbai06 Jul 2022AY 2004-05

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/wFor Respondent: Smt. Somogyan Pal, CIT DR
Section 115JSection 14ASection 250Section 80Section 80HSection 80M

…erpretation of a statute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In fact there are at least three decisions of this Court, one in Loka Shikshana Trust v. Commissioner of Income-Tax [1975] 101 ITR 234 (SC) the other in Indian Chamber of Commerce v. Commissioner of Income-tax [1975] 101 ITR 796 (SC) and the third in Additional Commissioner of Income-tax v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR 1 (SC) where the speech made by the Finance Minister while introducing the exclusionary clause in Section 2 Clause (15) of the Ac…

Tata Chemicals Ltd, Mumbai vs. DCIT 2(3), Mumbai

In the result, appeal by the Revenue is dismissed

ITA 2440/MUM/2011[2004-05]Status: DisposedITAT Mumbai06 Jul 2022AY 2004-05

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Nitesh Joshi a/wFor Respondent: Smt. Somogyan Pal, CIT DR
Section 115JSection 14ASection 250Section 80Section 80HSection 80M

…erpretation of a statute being an exercise in the ascertainment of meaning, everything which is logically relevant should be admissible. In fact there are at least three decisions of this Court, one in Loka Shikshana Trust v. Commissioner of Income-Tax [1975] 101 ITR 234 (SC) the other in Indian Chamber of Commerce v. Commissioner of Income-tax [1975] 101 ITR 796 (SC) and the third in Additional Commissioner of Income-tax v. Surat Art Silk Cloth Manufacturers Association [1980] 121 ITR 1 (SC) where the speech made by the Finance Minister while introducing the exclusionary clause in Section 2 Clause (15) of the Ac…

Income-Tax Officer (Exemptions), Pune vs. Chanakya Mandal Pariwar, Pune

ITA 835/PUN/2017[2012-13]Status: DisposedITAT Pune01 Jul 2022AY 2012-13

Bench: Shri S.S. Godara & Dr. Dipak P. Ripotethe Income Tax Officer M/S. Chanakya Mandal Pariwar (Exemptions) 1557, Sadashiv Peth Vs. Ward - 2, Pune Near Navi Peth Vitthalmandir Punne 411009 Pan – Aaatc6391G Appellant Respondent Co No. 06/Pun/2020 (Assessment Year: 2012-13) M/S. Chanakya Mandal Pariwar The Income Tax Officer 1557, Sadashiv Peth (Exemptions) Vs. Near Navi Peth Vitthalmandir Ward - 2, Pune Punne 411009 Pan – Aaatc6391G Cross Objector Appellant In Appeal Assessee By: Shri Hari Krishan Revenue By: Shri S.P. Walimbe Date Of Hearing: 25.04.2022 Date Of Pronouncement: 01.07.2022 O R D E R Per S.S. Godara, Jm This Revenue’S Appeal Ita No. 835/Pun/2017 With Assessee’S Cross Objection Co No. 06/Pun/2020 For Ay 2012-13 Arise From The Cit(A)-10, Pune’S Order Dated 30.01.2017 Passed In Case No. Pn/Cit(A)10/Ito Exmp Wd 1/44,45,46,47/15-16, Involving Proceedings Under Section 143(3) R.W.S 174 Of The Income Tax Act, 1961 (In Short The Act).

For Appellant: Shri Hari KrishanFor Respondent: Shri S.P. Walimbe
Section 11Section 11(1)(a)Section 143(3)Section 2(15)

…it was not falling within the meaning of education as contemplated uj s 2 (15) since, there was no formal primary educational activity. For this purpose, reliance was placed on the decision of H'ble Supreme Court in the case of Sole trustee Lok Shikshan Trust 101 ITR 234 wherein H'ble Supreme Court observed that the sense in which the word education has been used in section 2( 15) is the systematic institution, schooling or training given to the young in preparation for the work of life. It also connotes the whole course of scholastic instruction which a person has received ... what education connotes in that cla…

Indian Academy of Highway Engineers, Noida vs. CIT(E), Lucknow

ITA 645/DEL/2021[----]Status: DisposedITAT Delhi30 Jun 2022

Bench: Sh. G.S.Pannu, Hon’Ble & Sh. Anubhav Sharmaita No. 645 /Del/2021 (Assessment Year : ……..)

Section 10

…21 taxmann.com 281 (Madras. HC) 8. ITO vs. SRM Foundation of India, 21 ITD 598 (Delhi) 9. ITO, Ward 1, New Delhi vs. Science Olympaid Foundation, 48 taxmann.com 382 (ITAT) Indian Academy of Highway Engineers 5 10. Sole Trustee, Lok Shikshana Trust vs. CIT, 101 ITR 234 (SC) 11. Queen’s Education Society vs. CIT, 55 taxmann.com 255 (SC) 12. American Hotel & Lodging Association, Educational Institute vs. Central Board of Direct Taxes 13. Radhasoami Satsang vs. CIT, 60 Taxman. 248 (SC) 14. CIT vs. Excel Industries Ltd., 38 taxmann.com 100 (SC) 5. Ld. DR defended the orders of Ld. CIT(E), Lucknow submitting th…

Shree Maliya Kadva Patel Seva Samaj, Junagadh vs. The Income Tax Officer, Ward-1(3), Veraval

Appeal of the assessee is dismissed in above terms

ITA 187/RJT/2016[2011-12]Status: DisposedITAT Rajkot29 Jun 2022AY 2011-12
For Appellant: Shri Deepak Rindani, A.RFor Respondent: Shri S. S. Rathi, Sr. D.R
Section 11Section 13(1)(b)Section 250(6)

…eds to be examined whether such religious-charitable activity carried on by the trust only benefits a certain particular religious community or class or serves across the communities and for society at large. (Sole Trustee, Loka Shikshana Trust v. CIT, (1975) 101 ITR 234 (SC)). The section of community sought to be benefited must be either sufficiently defined or identifiable by a common quality of a public or impersonal nature. “ 23. Thus, in the present case also the provisions of section 13(1)(b) will apply, the trust being of charitable character with two of its objects exclusively for the benefit of the Ked…

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)

…nt of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. Ld. A.R. pointed out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as he shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. 15. He must then proceed to consider what is the meaning of the requirement that where the purpose of a trust or institution is advancement of an object of general public utility, such…

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)

…nt of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. Ld. A.R. pointed out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as he shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. 15. He must then proceed to consider what is the meaning of the requirement that where the purpose of a trust or institution is advancement of an object of general public utility, such…

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)

…nt of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. Ld. A.R. pointed out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as he shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. 15. He must then proceed to consider what is the meaning of the requirement that where the purpose of a trust or institution is advancement of an object of general public utility, such…

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)

…nt of the definition would be met and it is immaterial how the moneys for achieving or implementing such purpose are found, whether by carrying on an activity for profit or not. Ld. A.R. pointed out that even in Sole Trustee, LokaShikshana Trust v. CIT [1975] 101 ITR 234 (SC), a decision which, as he shall presently point out, does not command itself to us on another point, the same interpretation has been accepted by this Court. 15. He must then proceed to consider what is the meaning of the requirement that where the purpose of a trust or institution is advancement of an object of general public utility, such…