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“Section 10(15)”

Section References (mined)Section 10Section 10(15)157 judgments

The decision most relied on for Section 10(15) is Addl. CIT v. Surat Art Silk Cloth Manufacturers Association (121 ITR 1), cited in 328 judgments on BharatTax.

Leading authorities on Section 10(15)

Addl. CIT v. Surat Art Silk Cloth Manufacturers Association
121 ITR 1 · 1980 · Supreme Court
328
citing judgments

A charitable institution, whose predominant object is general public utility, can engage in non-charitable activities yielding incidental profits, provided these profits are deployed to achieve the dominant charitable object. A subsidiary object, if ancillary to the primary charitable purpose, does not negate the institution's charitable character.

CIT v. Yokogawa India Ltd.
341 ITR 385 · 2012 · High Court
270
citing judgments

A provision for doubtful debts cannot be added back while computing book profits under Section 115JB of the Income-tax Act for Minimum Alternate Tax (MAT) purposes.

CIT v. Madras Auto Service (P) Ltd.
233 ITR 468 · 1998 · Supreme Court
246
citing judgments

Expenditure providing an enduring advantage, such as upfront lease rent for land, is revenue expenditure if no capital asset is acquired or generated, allowing for deduction under Section 37, even when capitalized in the books of account.

Queen’s Educational Society v. CIT
372 ITR 699 · 2015 · Supreme Court
152
citing judgments

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.

India Trade Promotion Organization v. DGIT(Exemption)
371 ITR 333 · 2015 · High Court
128
citing judgments

An institution engaged in the advancement of general public utility retains its charitable character and eligibility for exemptions under Section 11 or approval under Section 10(23C)(iv) provided profit is not its predominant motive, even if it generates incidental surpluses or collects fees.

Khoday Distilleries Ltd. v. State of Karnataka
10 SCC 304 · 1996 · Reported
123
citing judgments

A 'trade' is primarily defined as the exchange of goods for goods or money, and secondarily as a business carried on with a view to profit. The term 'business' is more comprehensive than 'trade', encompassing manufacturing activities.

American Hotel and Lodging Association Educational Institute v. CBDT
301 ITR 86 · 2008 · Supreme Court
111
citing judgments

An educational institution is eligible for exemption under Section 10(23C)(vi) if it exists solely for educational purposes, even if it generates incidental profits. The mere existence of profit does not disqualify an institution from exemption.

(State of T.N v. Board of Trustees of the Port of Madras
4 SCC 630 · 1989 · Reported
108
citing judgments

An activity, even if it involves sales, does not constitute "business" for tax purposes if it is an incidental part of the main activities of a public utility entity and lacks a profit motive. The presence of a profit motive is generally essential to classify an activity as business.

Judgments citing Section 10(15)

United India Insurance Co Limited, Chennai vs. PCIT-3, Chennai

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

ITA 182/CHNY/2021[2015-16]Status: DisposedITAT Chennai05 Jan 2026AY 2015-16

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

For Appellant: Shri S. Sundararaman, CAFor Respondent: Ms. V. Pushpa, Sr. Standing Counsel
Section 10(38)Section 143(3)Section 263Section 44

correct for the very fact that deduction of dividends under sections 10(34) of the Act and deduction of interest under section 10(15) of the Act have been allowed for all assessment years without any dispute, and argued, it is amply clear that deduction under section 10 ... under section 10(38) of the Act. Further, income from VCF as tax is paid by fund, interest on tax free bonds under section 10(15)(i) of the Act, dividend income received from VCF under section 10(34) of the Act and dividend income under section 10

Lintas Employees Health Assistance Trust, Mumbai vs. Income Tax Officer Ward 25(2)(1), Mumbai

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

ITA 4364/MUM/2025[2019-20]Status: DisposedITAT Mumbai25 Sept 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon'Ble & Shri Girish Agrawalassessment Year: 2019-20 Lintas Employees Health Income-Tax Officer, Assistance Trust Ward – 25(2)(1), 13Th Floor, Express Towers Mumbai Nariman Point, Vs. Mumbai – 400021 (Pan: Aaatl0325M) (Appellant) (Respondent) Present For: Assessee : Shri Prakash Jotwani & Ms Priya Gada, Advocates Revenue : Shri Surendra Mohan, Sr. Dr Date Of Hearing : 14.08.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Girish Agrawal: This Appeal Filed By Assessee Is Against The Order Of Addl/Jcit (A)-1, Hyderabad Vide Order No. Itba/Apl/S/250/2024- 25/1074797264(1), Dated 21.03.2025 Passed Against The Intimation Issued By The Central Processing Centre Of The Department, Bengaluru (Cpc) U/S. 143(1) Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 12.05.2020 For Assessment Year 2019-20. 2. Grounds Taken By The Assessee Are Reproduced As Under: Ground No. 1: Erred In Not Condoning Delay In Filing The Appeal The Ld. Cit(A) Erred In Dismissing The Appeal Without Considering The Merits Of The Case & Erred In Not Condoning The Delay Of 964 Days In Filing The Appeal

For Appellant: Shri Prakash Jotwani and Ms Priya Gada, AdvocatesFor Respondent: Shri Surendra Mohan, Sr. DR
Section 10(15)Section 10(35)Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH MUMBAI BEFORE SHRI SAKTIJIT DEY, HON'BLE VICE PRESIDENT AND SHRI GIRISH