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

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 2087/BANG/2018[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

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 2086/BANG/2018[2010-11]Status: DisposedITAT Bangalore16 Jun 2022AY 2010-11

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 Kendra, Udupi vs. Assistant Commissioner of Income Tax, (Exemptions) Circle-1, Mangalore

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 1962/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…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 24/LKW/2017[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 23/LKW/2017[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 211/LKW/2017[2014-15]Status: DisposedITAT Lucknow08 Jun 2022AY 2014-15

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 210/LKW/2017[2013-14]Status: DisposedITAT Lucknow08 Jun 2022AY 2013-14

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 165/LKW/2017[2012-13]Status: DisposedITAT Lucknow08 Jun 2022AY 2012-13

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commisioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 164/LKW/2017[2011-12]Status: DisposedITAT Lucknow08 Jun 2022AY 2011-12

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 631/LKW/2016[2010-11]Status: DisposedITAT Lucknow08 Jun 2022AY 2010-11

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Astt. Commissioner of Income Tax (Exemption), Lucknow vs. M/S U.P Awas Evam Vikas Parishad, Lucknow

In the result, all the grounds taken in the appeals and ground 1 of additional grounds of the Revenue stand dismissed and additional ground

ITA 630/LKW/2016[2009-10]Status: DisposedITAT Lucknow08 Jun 2022AY 2009-10

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

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

…endering any services in relation to any trade, comer or business. 'In this decision, Page 41 of 242 (UP AWAS EVAM VIKAS PARISHAD) the Hon'ble Supreme Court approving the finding of Justice Beg in the case of Sole Trustee, Loka Sikhshana Trust's case [1975] 101 ITR 234, 256 (SC) held as under: "The test which has, therefore, now to be applied is whether the predominant object of the activity involved in carrying out the object of general public utility is to subserve the charitable purpose or to earn profit. Where profit making is the predominant object of the activity, the purpose though an object of general…

Income-Tax Officer (Exemptions), Pune vs. Mitra Technology Foundation, Pune

In the result of, appeal of Revenue is dismissed

ITA 796/PUN/2017[2009-10]Status: DisposedITAT Pune18 May 2022AY 2009-10

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

For Appellant: Shri Sharad ShahFor Respondent: Shri Piyushkumar Singh Yadav
Section 11Section 12ASection 2Section 2(15)Section 215

…] for assessment year 2009-10. 2. The only issue is to be decided is as to whether the CIT(A) is justified in allowing exemption u/s. 11 of the Act ignoring the ratio laid down by the Hon’ble Supreme Court in the case of Lok Shikshan Trust Vs. CIT reported in 101 ITR 234 (SC). 2 ITA No.796/PUN/2017, A.Y. 2009-10 3. The brief facts relating to the issue on hand are that the assessee is an AOP duly registered u/s. 12AA of the Act vide order dated 05-12-2002 w.e.f. 18-12-2001. The AO on an examination of objects, held the assessee is to be considered under the fourth limb of sub-section (15) of section 2 i.e. any…

Investor Financial Education Academy, Chennai vs. ITO (Exemption) - 4, Chennai

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

ITA 3007/CHNY/2018[2018-19]Status: DisposedITAT Chennai12 Apr 2022AY 2018-19

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 12ASection 2(15)Section 25Section 80G(5)(vi)

…ning centres and colleges for various courses having a bearing on the field of co-operative movement. It appears to us that the decision of the Tribunal which seeks to rest it on the observations made by the Supreme Court in Loka Shikshana Trust's case [1975] 101 ITR 234, for holding that, the assessee is not entitled to exemption under section 10(22) of the Act is based on a complete misreading of the observations of the Supreme Court. In Loka Shikshana Trust's case [1975] 101 ITR 234, the Supreme Court, while dealing with the provisions of section 11 read with section 2(15) of the Act which defines "charitable…

Investor Financial Education Academy, Chennai vs. ITO (Exemption) - 4, Chennai

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

ITA 3006/CHNY/2018[2018-19]Status: DisposedITAT Chennai12 Apr 2022AY 2018-19

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri M. Rajan, CIT
Section 12ASection 2(15)Section 25Section 80G(5)(vi)

…ning centres and colleges for various courses having a bearing on the field of co-operative movement. It appears to us that the decision of the Tribunal which seeks to rest it on the observations made by the Supreme Court in Loka Shikshana Trust's case [1975] 101 ITR 234, for holding that, the assessee is not entitled to exemption under section 10(22) of the Act is based on a complete misreading of the observations of the Supreme Court. In Loka Shikshana Trust's case [1975] 101 ITR 234, the Supreme Court, while dealing with the provisions of section 11 read with section 2(15) of the Act which defines "charitable…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 291/DEL/2020[2016-17]Status: DisposedITAT Delhi23 Mar 2022AY 2016-17

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 5277/DEL/2019[2014-15]Status: DisposedITAT Delhi23 Mar 2022AY 2014-15

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 5276/DEL/2019[2012-13]Status: DisposedITAT Delhi23 Mar 2022AY 2012-13

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 5275/DEL/2019[2010-11]Status: DisposedITAT Delhi23 Mar 2022AY 2010-11

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 5274/DEL/2019[2009-10]Status: DisposedITAT Delhi23 Mar 2022AY 2009-10

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…

Jaibharat Mandal Ramlila and Dharamshala Society, Hisar vs. ITO (Exemption), Rohtak

ITA 5273/DEL/2019[2008-09]Status: DisposedITAT Delhi23 Mar 2022AY 2008-09

Bench: Shri Kul Bharat1. Ita No. 5273/Del/2019 (A.Y. 2008-09) 2. Ita No. 5274/Del/2019 (A.Y. 2009-10) 3. Ita No. 5275/Del/2019 (A.Y. 2010-11) 4. Ita No. 5276/Del/2019 (A.Y. 2012-13) 5. Ita No. 5277/Del/2019 (A.Y. 2014-15) 6. Ita No. 291/Del/2020 (A.Y. 2016-17)

Section 12ASection 147Section 148

…a business is being carried on, means no more than that profit is to be earned by a process of production. ” Reliance in this regard is further placed on the decision of the hon’ble Supreme Court in the case of Sole Trustee, Loka Shikshana Trust v. CIT [1975] 101 ITR 234 (SC) wherein it has been held that: 13 ITA 5273 to 5277/D/19 & 291/D/20 Jaibharat Mandal Ramlila & Dharamshala Society Vs. ITO “The difficult question, however, still remains: What is the meaning of "charitable purpose" which is only indicated but not defined by section 2(15) of the Act? It seems to me that a common concept or element of "charit…