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“proviso to section 2(15)”

Charitable TrustsSection 2(15)Section 2(15)581 judgments

The decision most relied on for proviso to section 2(15) is ACIT v. Ahmedabad Urban Development Authority (143 Taxmann.com 278), cited in 390 judgments on BharatTax.

Leading authorities on proviso to section 2(15)

ACIT v. Ahmedabad Urban Development Authority
143 Taxmann.com 278 · 2022 · Supreme Court
390
citing judgments

If activities for the advancement of general public utility are carried on as a business, income from such activities is not exempt under Section 11, even if the profits are utilized for the main charitable object. The argument that profits from general public utility activities can be ploughed back to charity to maintain exemption is not a good law.

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.

362 ITR 539 (Gujarat) (d) Institute of Chartered Accountants of India v. DGIT
347 ITR 99 · 2012 · High Court
112
citing judgments

The broad definition of 'business' should not be applied when interpreting the proviso to Section 2(15) of the Income-tax Act, 1961, as the object and purpose of the section must be considered.

Ahmedabad Urban Development Authority v. ACIT
396 ITR 323 · 2017 · High Court
108
citing judgments

Development authorities can continue to be regarded as existing for a 'Charitable Purpose' under Section 2(15) of the Income Tax Act, even after the introduction of the proviso to that section. The contention that such authorities automatically lose their charitable status due to the proviso is incorrect.

Institute of Chartered Accountants of India (ICAI) v. DGIT (Exemptions)
358 ITR 91 · 2013 · High Court
80
citing judgments

An institution carrying out charitable objects, such as education or advancement of general public utility, does not lose its Section 11 exemption merely by collecting fees for activities like campus placements or educational guidance, as this does not constitute carrying on a business.

DIT v. Sabarmati Gaushala Trust
362 ITR 539 · 2014 · High Court
63
citing judgments

Activities of a trust established for the advancement of general public utility do not constitute a 'business' activity if undertaken without private motive, thus qualifying for exemption under Section 11 read with Section 2(15), even when charging fees or receiving consideration.

Commissioner of Sales Tax v. Sai Publication Fund
258 ITR 70 · 2002 · Supreme Court
62
citing judgments

If a charitable organization's dominant activity is not business, then any incidental or ancillary activity performed to achieve its main object will also not be considered 'business,' even if it generates income, provided the primary activity is not driven by a profit intent.

Judgments citing proviso to section 2(15)

M/S. Karnataka State Seed & Organic Certification Agency, Bengaluru vs. The Commissioner of Income Tax (Exemptions), Bengaluru

In the result, the appeals filed by the assessee are dismissed

ITA 518/BANG/2021[2017-18]Status: DisposedITAT Bangalore20 Jul 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Mallah Rao, AdvocateFor Respondent: Sri.Srinivas T.Bidari, CIT-DR
Section 10Section 11Section 12ASection 143(3)Section 263

commerce or business. Therefore, the activities squarely falls within the ambit of 4 ITA Nos.517 & 518/Bang/2021. M/s.Karnataka State Seed & Organic Certification Agency. proviso to section 2(15) of the I.T.Act. The assessee filed objections to the proposed orders u/s 263 of the I.T.Act. However, the objections of the assessee were ... held that the assessee is not carrying out any charitable activities and in view of the proviso to section 2(15) of the I.T.Act, the assessee is not entitled to exemption u/s 11 and 12 of the I.T.Act. In taking the above view, the CIT(E) relied on the judgment

M/S. Karnataka State Seed & Organic Certification Agency, Bengaluru vs. The Commissioner of Income Tax (Exemptions), Bangalore

In the result, the appeals filed by the assessee are dismissed

ITA 517/BANG/2021[2016-17]Status: DisposedITAT Bangalore20 Jul 2022AY 2016-17

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Mallah Rao, AdvocateFor Respondent: Sri.Srinivas T.Bidari, CIT-DR
Section 10Section 11Section 12ASection 143(3)Section 263

commerce or business. Therefore, the activities squarely falls within the ambit of 4 ITA Nos.517 & 518/Bang/2021. M/s.Karnataka State Seed & Organic Certification Agency. proviso to section 2(15) of the I.T.Act. The assessee filed objections to the proposed orders u/s 263 of the I.T.Act. However, the objections of the assessee were ... held that the assessee is not carrying out any charitable activities and in view of the proviso to section 2(15) of the I.T.Act, the assessee is not entitled to exemption u/s 11 and 12 of the I.T.Act. In taking the above view, the CIT(E) relied on the judgment

Income Tax Officer (Exemptions), Ward-3, Bangalore vs. M/S. Kanakapura Planning Authority, Bangalore

In the result, the appeals filed by the Department are dismissed

ITA 399/BANG/2022[2017-18]Status: DisposedITAT Bangalore15 Jul 2022AY 2017-18

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Priyadarshini Baseganni, Addl.CIT-DRFor Respondent: --- None ---
Section 11Section 12ASection 2(15)Section 260A

fact that the activities of the assessee are in the nature of trade, commerce or business and therefore hit by the first Proviso to section 2(15) of the Act. 5. Any other grounds which may arise at the time of hearing. 6. The order of the learned ... completed by denying the benefit of exemption u/s 11 of the I.T.Act. The Assessing Officer held that the assessee is hit by proviso to section 2(15) r.w.s. 13(8) of the I.T.Act and irrespective of the fact that the assessee registration u/s 12AA of the I.T.Act is in force

Income Tax Officer (Exemptions), Ward-3, Bangalore vs. M/S. Kanakapura Planning Authority, Bangalore

In the result, the appeals filed by the Department are dismissed

ITA 398/BANG/2022[2015-16]Status: DisposedITAT Bangalore15 Jul 2022AY 2015-16

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Priyadarshini Baseganni, Addl.CIT-DRFor Respondent: --- None ---
Section 11Section 12ASection 2(15)Section 260A

fact that the activities of the assessee are in the nature of trade, commerce or business and therefore hit by the first Proviso to section 2(15) of the Act. 5. Any other grounds which may arise at the time of hearing. 6. The order of the learned ... completed by denying the benefit of exemption u/s 11 of the I.T.Act. The Assessing Officer held that the assessee is hit by proviso to section 2(15) r.w.s. 13(8) of the I.T.Act and irrespective of the fact that the assessee registration u/s 12AA of the I.T.Act is in force

Income Tax Officer (Exemptions), Ward-3, Bangalore vs. M/S. Kanakapura Planning Authority, Bangalore

In the result, the appeals filed by the Department are dismissed

ITA 397/BANG/2022[2014-15]Status: DisposedITAT Bangalore15 Jul 2022AY 2014-15

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Priyadarshini Baseganni, Addl.CIT-DRFor Respondent: --- None ---
Section 11Section 12ASection 2(15)Section 260A

fact that the activities of the assessee are in the nature of trade, commerce or business and therefore hit by the first Proviso to section 2(15) of the Act. 5. Any other grounds which may arise at the time of hearing. 6. The order of the learned ... completed by denying the benefit of exemption u/s 11 of the I.T.Act. The Assessing Officer held that the assessee is hit by proviso to section 2(15) r.w.s. 13(8) of the I.T.Act and irrespective of the fact that the assessee registration u/s 12AA of the I.T.Act is in force

Income Tax Officer (Exemptions), Ward-3, Bangalore vs. M/S. Kanakapura Planning Authority, Bangalore

In the result, the appeals filed by the Department are dismissed

ITA 396/BANG/2022[2013-14]Status: DisposedITAT Bangalore15 Jul 2022AY 2013-14

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Priyadarshini Baseganni, Addl.CIT-DRFor Respondent: --- None ---
Section 11Section 12ASection 2(15)Section 260A

fact that the activities of the assessee are in the nature of trade, commerce or business and therefore hit by the first Proviso to section 2(15) of the Act. 5. Any other grounds which may arise at the time of hearing. 6. The order of the learned ... completed by denying the benefit of exemption u/s 11 of the I.T.Act. The Assessing Officer held that the assessee is hit by proviso to section 2(15) r.w.s. 13(8) of the I.T.Act and irrespective of the fact that the assessee registration u/s 12AA of the I.T.Act is in force

Income Tax Officer (Exemptions), Ward-3, Bangalore vs. M/S. Kanakapura Planning Authority, Bengaluru

In the result, the appeals filed by the Department are dismissed

ITA 395/BANG/2022[2012-13]Status: DisposedITAT Bangalore15 Jul 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Priyadarshini Baseganni, Addl.CIT-DRFor Respondent: --- None ---
Section 11Section 12ASection 2(15)Section 260A

fact that the activities of the assessee are in the nature of trade, commerce or business and therefore hit by the first Proviso to section 2(15) of the Act. 5. Any other grounds which may arise at the time of hearing. 6. The order of the learned ... completed by denying the benefit of exemption u/s 11 of the I.T.Act. The Assessing Officer held that the assessee is hit by proviso to section 2(15) r.w.s. 13(8) of the I.T.Act and irrespective of the fact that the assessee registration u/s 12AA of the I.T.Act is in force

M/S Federation of Freight Forwarders Associations in India, Mumbai vs. ITO 1(3), Mumbai

In the result, ground no.1 of the assessee is allowed and additions amounting to Rs

ITA 710/MUM/2020[2014-15]Status: DisposedITAT Mumbai07 Jul 2022AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri Gagan Goyalm/S Federation Of Freight Forwarders Associations, 311/313, Mahinder Chambers, W.T. Patil Marg, Opp. Dukes Factory, Chembur, Mumbai-400071 Pan: Aaatf0039J ...... Appellant Vs. Ito (Exemption)-1(3), Piramal Chambers 4Th Floor, Dr. S.S. Road, Parel, Mumbai-400012. ..... Respondent Appellant By : Sh. Nitesh Joshi Respondent By : Sh. Indira Adakil, Cit-Dr Date Of Hearing : 13/04/2022 Date Of Pronouncement : 07/07/2022 Order Per Gagan Goyal, A.M:

For Appellant: Sh. Nitesh JoshiFor Respondent: Sh. Indira Adakil, CIT-DR
Section 11Section 11(5)Section 12ASection 142(1)Section 2Section 2(15)

their activities are restricted to contributions from and participation of only their members, these would fall under the purview of the proviso to section 2(15) owing to the principle of mutuality, organizations have dealings with non-members, their claim to be charitable organizations would now be governed ... additional conditions stipulated in the proviso to section 2 (15)." 5. AO further held as under: “4.3 Further, the assessee in its submission gives reference to provision of investment of interest within the meaning of section 11(5) of the IT Act. However, the assessee failed to pay heed

Gymnastics Sevabhavai Sanstha, Mumbai vs. CIT (Exemption), Pune

In the result, appeal filed by the assessee is partly allowed with above directions

ITA 2010/MUM/2020[2020-21]Status: DisposedITAT Mumbai07 Jul 2022AY 2020-21

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Cit Exemption, Pune Gymnastics Sevabhavi Sanstha Room No. 322, 3Rd Floor, Flat No. 101, Building No.4, Income Tax Office, Raunak Park, Pokharan Road, Pmt Building, Vs. No.2, Kokanipada, Thane (W) Shankar Seth Road, Mumbai-400 606 Pune- 411 037 (Respondent) (Appellant) Pan No.Aactg 7323 G Assessee By : Shri Subodh Ratnaparkhi, Ar Revenue By : Shri Ashok Koli, Cit Dr Date Of Hearing: 01.06.2022 Date Of Pronouncement : 07.07.2022

For Appellant: Shri Subodh Ratnaparkhi, ARFor Respondent: Shri Ashok Koli, CIT DR
Section 12ASection 15Section 2Section 2(15)

under category of advancement of any other object of general public utility u/s 2(15) of the Act and therefore as per proviso to section 2(15) and for other unjustified reasons, the appellant was not entitled for and registration, which view being factually and legally incorrect, the registration ... October, 2020, holding that the object and activity claimed by the assessee are not charitable in nature in view of the proviso to Section 2(15) of the Act. 05. The object of the assessee shows that it is set up for carrying out the activities such as preparing players

Income Tax Officer(Exemption) Ward-1(1), Mumbai vs. Association of Physicians of India, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 974/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Jun 2022AY 2017-18
Section 11Section 143Section 2(15)Section 28

relation to any trade, commerce or business for a cess or fee or any other consideration and are hit by the proviso to section 2(15) of the I.T. Act?" ITA Nos.: 971 to 974/Mum/2022 Assessment years: 2014-15 to 2017-18 Page 2 of 8 2. "Whether ... exempted income u/s 11 of the Act, ignoring the fact that activities of the assessee hit by the proviso to section 2(15) of the Act and not entitled for exemption u/s 11 of the Act and therefore receipt from corpus donation to be taxed as per provisions of section

Income Tax Officer (Exemption), Ward-1(1), Mumbai vs. Association of Physicians of Indiaf, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 973/MUM/2022[2016-17]Status: DisposedITAT Mumbai30 Jun 2022AY 2016-17
Section 11Section 143Section 2(15)Section 28

relation to any trade, commerce or business for a cess or fee or any other consideration and are hit by the proviso to section 2(15) of the I.T. Act?" ITA Nos.: 971 to 974/Mum/2022 Assessment years: 2014-15 to 2017-18 Page 2 of 8 2. "Whether ... exempted income u/s 11 of the Act, ignoring the fact that activities of the assessee hit by the proviso to section 2(15) of the Act and not entitled for exemption u/s 11 of the Act and therefore receipt from corpus donation to be taxed as per provisions of section

Income Tax Officer(Exemption)Ward-1(1), Mumbai vs. Association of Physicians of India, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 972/MUM/2022[2015-16]Status: DisposedITAT Mumbai30 Jun 2022AY 2015-16
Section 11Section 143Section 2(15)Section 28

relation to any trade, commerce or business for a cess or fee or any other consideration and are hit by the proviso to section 2(15) of the I.T. Act?" ITA Nos.: 971 to 974/Mum/2022 Assessment years: 2014-15 to 2017-18 Page 2 of 8 2. "Whether ... exempted income u/s 11 of the Act, ignoring the fact that activities of the assessee hit by the proviso to section 2(15) of the Act and not entitled for exemption u/s 11 of the Act and therefore receipt from corpus donation to be taxed as per provisions of section

Income Tax Officer (Exemption) Ward-1(1), Mumbai vs. Association of Physicians of India, Mumbai

In the result, Ground No.1 of the assessee‟s appeal is allowed

ITA 971/MUM/2022[2014-15]Status: DisposedITAT Mumbai30 Jun 2022AY 2014-15
Section 11Section 143Section 2(15)Section 28

relation to any trade, commerce or business for a cess or fee or any other consideration and are hit by the proviso to section 2(15) of the I.T. Act?" ITA Nos.: 971 to 974/Mum/2022 Assessment years: 2014-15 to 2017-18 Page 2 of 8 2. "Whether ... exempted income u/s 11 of the Act, ignoring the fact that activities of the assessee hit by the proviso to section 2(15) of the Act and not entitled for exemption u/s 11 of the Act and therefore receipt from corpus donation to be taxed as per provisions of section

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru

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)

with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru ... with regard to denying of exemption u/s 11 of the Income-tax Act,1961 ['the Act' for short] by invoking the first proviso to section 2(15) of the Act. ITA No.947&948 /Bang/2019, ITA 1962/Bang/2018 & ITA Nos.2086 to 2089/Bang/2018 M/s. Udupi Nirmithi Kendra, Udupi & Dakshina Kannada Nirmithi Kendra, Manguluru