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“Section 2(15)”

Section References (mined)Section 2Section 2(15)1,405 judgments

The decision most relied on for Section 2(15) is 279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises (298 ITR 141), cited in 706 judgments on BharatTax.

Leading authorities on Section 2(15)

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

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.

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.

Sole Trustee, Loka Shikshana Trust v. CIT
101 ITR 234 · 1975 · Supreme Court
323
citing judgments

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.

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. Andhra Chamber of Commerce
55 ITR 722 · 1965 · Supreme Court
167
citing judgments

An organization qualifies as having a charitable purpose if its primary object is the advancement of general public utility, even if its members receive incidental benefits. The existence of incidental non-charitable objects does not negate its charitable status.

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.

Judgments citing Section 2(15)

SHI vs. Iddhi Education Society, Sataravs.CIT Exemption Pune, Pune

In the result, appeal filed by the assessee is allowed

ITA 1774/PUN/2025[2024-25]Status: DisposedITAT Pune24 Sept 2025AY 2024-25

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1774 & 1786/Pun/2025 निर्धारण वषा / Assessment Year: - Shivsiddhi Education Society, V The Cit Exemption, 10, S.No.272/A, Midc S. Pune. Chandan Nagar, Degaon, Satara – 415004. Pan: Aapts1266F Appellant/ Assessee Respondent / Revenue Assessee By Ca Rani C. Mutha Revenue By Shri Amit Bobde- Cit Date Of Hearing 10/09/2025 Date Of Pronouncement 24/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application For Grant Of Registration U/S.12A R.W.S 12Ab & 80G(5) Of The Income Tax Act, 1961(Hereinafter Referred To As „The Act‟) Both Dated 20.09.2024Respectively. For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat The Appeal In Ita

Section 11Section 12ASection 12A(1)(ac)

duly approved by Competent Authorities of the Maharashtra State Government. Running a duly approved school is a Charitable Activity as defined in Section 2(15) of the Income Tax Act. 11.1 Ld.CIT(E) has not contradicted these facts. No violation of any other law applicable has been brought on record ... documents filed before the ld.Commissioner of Income Tax(Exemption), we are convinced that Assessee‟s objects are Charitable in nature as defined in section 2(15) of the Act, the activity of running an approved school is as per the objects, Genuineness of activity is established by the documents

Msb Educational Society, Kota, Rajasthan vs. CIT(E) Jaipur, Jaipur, Rajasthan

In the result, this last objection also no more stands on its legs

ITA 155/JPR/2025[2025-26]Status: DisposedITAT Jaipur23 Sept 2025AY 2025-26

Bench: Shri Gagan Goyal & Shri Narinder Kumarmsb Educational Society, Plot No. 1, Burhani Park, Ward No. 1, Ramnagar Nanta, Kota 324 008 Pan No. Aaqam 8644P ...... Appellant Vs.

For Appellant: Mr. Ankit Chokshi, CA, Ld. AR (thro. VC)For Respondent: Mr. Rajesh Ojha, CIT, Ld. DR
Section 12ASection 17

phrase charitable purpose is expansive and inclusive. The expression 'charitable purpose' is defined in the dictionary clause of the Act under section 2(15). [Para 29] According to section 2(15), the expression 'charitable purpose' has been defined by way of an inclusive definition so as to include relief ... impart religious education to the masses would qualify as a charitable purpose qualifying under the head of education under the provisions of section 2(15) of the Act. The institutions established to spread religious awareness by means of education though established to promote and further religious thought could

Shree Vardhman Samaj Utkarsh Fund, Sabarkantha vs. The CIT(Exemption), Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 427/AHD/2025[NA]Status: DisposedITAT Ahmedabad23 Sept 2025

Bench: DR. BRR Kumar (Vice President), Shri Siddhartha Nautiyal (Judicial Member)

Section 2(15)Section 80GSection 80G(5)Section 80G(58)

trust benefits only a specific religious community. The appellant provides assistance based on need, irrespective of caste or religion, in alignment with section 2(15) of the Act. Assessing Officer failed to review financial statements and Audit report whereby it clearly exhibits that the amount received as donations were utilised

Wellness Charitable Trust, Bengaluru vs. Commissioner of Income Tax, (Exemptions), Bangalore

In the result, the appeal of the assessee is hereby allowed

ITA 366/BANG/2025[2025-26]Status: DisposedITAT Bangalore23 Sept 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Murali Mohan, CIT (DR)
Section 12A

poor, medical aid, and promotion of yoga. Hence the objects of the appellant assessee squarely fall within “charitable purpose” as defined under section 2(15) of the Act. Within few months, i.e. for year ending 31st March 2022 it received donation aggregating to Rs. 8,38,910/- and applied entire

Wellness Charitable Trust, Bangalore vs. Commissioner of Income Tax, (Exemptions), Bangalore

ITA 365/BANG/2025[2025-26]Status: DisposedITAT Bangalore23 Sept 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Ravish Rao, CAFor Respondent: Shri Murali Mohan, CIT (DR)
Section 12A

IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL

The New Education Society, Thane vs. CIT-Exemption, Pune

In the result, appeal filed by the assessee is allowed

ITA 1324/PUN/2025[Not Applicable]Status: DisposedITAT Pune22 Sept 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं./Ita Nos.1323 & 1324/Pun/2025 निर्धारण वषा / Assessment Year :- The New Education Society, V The Commissioner Of 1, Opp Sai Arcade, Netaji S. Income Tax, Exemption, Chowk, G S Pammani Marg, Pune. Ulhasnagar, Thane – 421004. Pan: Aaatt7011L Appellant/ Assessee Respondent / Revenue Assessee By Ms. Sailee Gujarathi Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 09/09/2025 Date Of Pronouncement 22/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application For Grant Of Registration U/S.12A R.W.S 12Ab & 80G(5) Of The Income Tax Act, 1961(Hereinafter Referred To As „The Act‟) Both Dated 27.01.2024 Respectively. For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being

Section 12ASection 12A(1)(ac)Section 3

understand that the Aims and Objects of the Assessee society are mainly educational, the objects are charitable in nature as defined in section 2(15) of the Income Tax Act. 5 ITA Nos.1323& 1324/PUN/2025 [A] 4.9 We have already mentioned that the Assessee is duly registered with the Charity Commissioner ... documents filed before the ld.Commissioner of Income Tax(Exemption), we are convinced that Assessee‟s objects are Charitable in nature as defined in section 2(15) of the Act, the activity of running an approved school and college is as per the objects, Genuineness of activity is established

The New Education Society, Thane vs. CIT-Exemption, Pune

In the result, appeal filed by the assessee is allowed

ITA 1323/PUN/2025[Not Applicable]Status: DisposedITAT Pune22 Sept 2025
Section 12ASection 12A(1)(ac)

understand that the Aims and Objects of the Assessee society are mainly educational, the objects are charitable in nature as defined in section 2(15) of the Income Tax Act. 4.9 We have already mentioned that the Assessee is duly registered with the Charity Commissioner. Copy of the said Certificate ... documents filed before the ld.Commissioner of Income Tax(Exemption), we are convinced that Assessee's objects are Charitable in nature as defined in section 2(15) of the Act, the activity of running an approved school and college is as per the objects, Genuineness of activity is established

The Jewellers and Diamond Traders Association, Madras vs. CIT, Exemptions, Chennai

In the result, the appeal of the assessee is allowed

ITA 1093/CHNY/2025[-]Status: DisposedITAT Chennai22 Sept 2025

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

For Appellant: Mr. V. Swaminathan, C.AFor Respondent: Mr. Bipin C.N., CIT
Section 12ASection 2(15)

activities of the society cannot be held as advancement of any other objects of general public utility and ultimately charitable as defined in Section 2(15) of the Income Tax Act. From the above facts of the case and the points of discussion, it is seen that the object ... whether the quantum from these receipts, and other such receipts are within the limit prescribed by the sub-clause (ii) to proviso to section 2(15). If they are within the limits, AEPC would be - for that year, entitled to claim benefit as a GPU charity” 9. Further

Aditya Birla Education Trust, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 4474/MUM/2025[NA]Status: DisposedITAT Mumbai19 Sept 2025

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

For Appellant: Shri Saurabh Soparkar (virtually appear), Shri Yogesh Thar, ShriFor Respondent: Shri Rajesh Kumar Yadav (CIT-DR)
Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)

Supreme Court and also looking to the facts that assessee society is providing education, medical facility, relief to poor as defined in section 2(15) of the Act which has not been doubted by the Ld. CIT(E) who merely for the reason that major beneficiaries are from a particular ... Sole Trustee Lok Shikshana Trust, reported in 101 ITR 234 has clearly laid down that the scope of education within the meaning of section 2(15) is confined to formal education only, and does not extend to any wider connotation. The relevant findings of Hon'ble Supreme Court

Vishwa Nirmala Dharma Trust Jamshedpur, Jamshedpur vs. Exemption Ward, Jsr, Jamshdpur

Appeal of the assessee is allowed

ITA 306/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

Vishwa Nirmala Dharma Trust Jamshedpur, Jamshedpur vs. Exemption Ward, Jsr, Jamshedpur

Appeal of the assessee is allowed

ITA 305/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

G D Rungta Foundation, Jamshedpur vs. Exemption Ward, Jsr, Jamshedpur

Appeal of the assessee is allowed

ITA 304/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

G D Rungta Foundation, Jamshedpur vs. Exemption Ward, Jsr, Jamshedpur

Appeal of the assessee is allowed

ITA 303/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

Satyalok Kriya Yoga, Jamshedpur vs. Exemption Ward, Jsr, Jamshedpur

Appeal of the assessee is allowed

ITA 301/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

Satyalok Kriya Yoga, Jamshedpur vs. Exemption Ward, Jsr, Jamshedpur

Appeal of the assessee is allowed

ITA 300/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi18 Sept 2025

Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)

Section 10Section 11Section 12ASection 2(15)Section 80G

wholly for charitable Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause ... trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly

Advantage India, New Delhi vs. Pr.CIT (Central)-II, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 634/DEL/2019[-]Status: DisposedITAT Delhi18 Sept 2025

Bench: Shri Vikas Awasthy & Shri Naveen Chandra

For Appellant: Shri Sanjay Mehra, FCAFor Respondent: Shri Javed Akhtar, CIT [DR]
Section 127Section 127(2)Section 12ASection 13(1)(c)

registration already granted u/s 11 to a charitable institution merely on the ground that the cut-off specified in the proviso to section 2(15) of the Act is exceeded in a particular year without there being any change in the nature of activities of the institution. The case laws

Sree Vishwabharathi Charitable Trust, Bengaluru vs. ITO Ward 3(2)(1), Benglauru, Bengaluru

In the result appeal of the assessee is hereby partly allowed for statistical purposes

ITA 859/BANG/2025[2018-19]Status: DisposedITAT Bangalore16 Sept 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

For Appellant: Shri K.H Nagaraj, CAFor Respondent: Shri Ganesh R Ghale, Advocate – Standing
Section 10Section 12ASection 143(1)(a)Section 144Section 2(15)Section 69C

notices sought information to substantiate the incidental activities in relation to the main object and . Page 3 of 8 to show compliance with section 2(15) of the Act. The assessee did not respond. 7. Accordingly, the AO completed the assessment under section 144 of the Act. Since the assessee

Shri Narnauliye Agrawal Sewa Samiti, Sherghati Gaya vs. CIT Exemption, Patna

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 69/PAT/2025[2025-26]Status: DisposedITAT Patna15 Sept 2025AY 2025-26

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 12ASection 80G

accordance with the object of the society only for charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act and the application was rejected and the provisional registration granted u/s 12A(1)(ac)(vi) of the Act in Form-10AC dated

Shri Narnauliye Agrawal Sewa Samiti, Sher Ghati Gaya vs. CIT Exemption, Patna

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

ITA 68/PAT/2025[2025-26]Status: DisposedITAT Patna15 Sept 2025AY 2025-26

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 12ASection 80G

accordance with the object of the society only for charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act and the application was rejected and the provisional registration granted u/s 12A(1)(ac)(vi) of the Act in Form-10AC dated

Credit Guarantee Fund Trust for Micro and Small Enterprises, Mumbai vs. Deputy Commissioner of Income Tax Exemption -1(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4699/MUM/2025[2018-19]Status: DisposedITAT Mumbai15 Sept 2025AY 2018-19

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyassessment Year : 2018-19 Credit Guarantee Fund Trust Deputy Commissioner Of For Micro & Small Enterprises, Income Tax, Exemption-1(1), 1St Floor, Vs. Mtnl Tel. Exch. Building, Sidbi Swavalamban Bhavan, Cumballa Hills, Pedder Road, Avenue 3, Lane 2, G-Block, Mumbai-400026. Bandra Kurla Complex, Bandra (East), Mumbai-400051. Pan : Aaatc2613D (Appellant) (Respondent) For Assessee : Shri Shailesh Shah & Shri Jay Dharod For Revenue : Shri R.A. Dhyani, Cit-Dr Date Of Hearing : 04-09-2025 Date Of Pronouncement : 15-09-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Pertaining To Assessment Year (Ay) 2018-19, Wherein The Assessee Has Taken The Following Grounds Of Appeal: “(1) On The Facts & Circumstances Of The Case & In Law, The Learned Commissioner Of Income Tax (Appeals) [Ld. Cit(A)], Nfac Has Erred In Confirming The Order Of Levying Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- On 2 Disallowances Made In The Assessment Order Passed U/S 143(3) R.W.S 144B Of The Act Without Appreciating The Fact That The Hon'Ble Itat, Mumbai Has Fully Deleted The Said Disallowances & Reasons Assigned By Him For Doing So Are Wrong & Contrary To The Facts & Circumstances Of The Case, Provisions Of The Act & Income Tax Rules, 1962 ("The Rules") Made Thereunder. The Appellant Prays That The Penalty U/S 270A Of The Act Of Rs. 293,63,60,258/- Be Deleted. The Appellant Craves Leave To Add, Amend, Alter, Modify And/Or Delete All Or Any Of The Above Grounds Of Appeal, On Or Before The Date Of Hearing.”

For Appellant: Shri Shailesh Shah &For Respondent: Shri R.A. Dhyani, CIT-DR
Section 11Section 12ASection 143Section 143(3)Section 144Section 2(15)Section 270A

assessment order for AY. 2016-17 & 2017-18, the AO proceeded to hold that the assessee‟s case is covered by proviso to section 2(15) of the Act and thereby rejected the claim of exemption under section 11 of the Act and whole of income amounting ... facts the assessee trust has claimed benefits available under section 11 & 12 of the Act. However, the AO by invoking the proviso to section 2(15) of the Act and by relying upon the assessment order for A.Y. 2016-17 & 2017-18 denied the claim of exemption under section