“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)

Ramrao Adik Education Society, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 7(1), Mumbai

Accordingly. The ground raised by the revenue is partly allowed for

ITA 1509/MUM/2025[2011-12]Status: DisposedITAT Mumbai04 Sept 2025AY 2011-12

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

Section 12ASection 132Section 132(4)Section 153CSection 250Section 68Section 9

assessee are not in accordance with its objectives and that the same does not fall within the definition of "charitable purpose" as per section 2(15) of the Act due to which the assessee cannot claim the benefit under section 11 of the Act. The AO accordingly assessed the assessee

Improvement Trust, Rajpura vs. ITO Exemption, Chandigarh

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

ITA 419/CHANDI/2025[2017-18]Status: DisposedITAT Chandigarh03 Sept 2025AY 2017-18

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 419/Chd/2025 "नधा"रण वष" / Assessment Year : 2017-18 Improvement Trust, Ito, Exemption, Rotary Club Road, बनाम Chandigarh. Rajpura. 140401 Vs. Distt. Patiala "थायी लेखा सं./Pan No: Aaati4964R अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Shri. Hukminder Shahi, C.A. राज"व क" ओर से/ Revenue By : Shri Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 30-07-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 03.09-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 28-02-2024 Of Ld. Addl. / Jcit(A)- 1, Noida For Ay 2017-18. 2. Grounds Of Appeal Raised & Relief Claimed /Prayer Made By The Assessee Are As Under:

For Appellant: Shri. Hukminder Shahi, C.AFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 11Section 13(8)Section 2(15)Section 240

holding that assessee is not entitled for the benefit of exemption u/s 11 of the Income Tax Act, 1961, with respect to Section 2(15) read with Section 13(8) of the Act. 4. That, on the facts and circumstances of the case, and in law, the Worthy

Acharya Sri Tulsi Mahapragya Seva Kendra Charitable Trust, Bangalore vs. CIT(Exemptions), Bangalore

ITA 951/BANG/2025[NA]Status: HeardITAT Bangalore03 Sept 2025

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

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

Tulasi Vidya Vihar school, operating Chetana Arogyam naturopathy center, constructing an old age home, etc and all these activities are compliant with section 2(15) of the Act. 6. The learned CIT(Exemptions) has erred in concluding that the naturopathy services at Chetana Arogyam are commercial in nature

Sheth Sobhagchand Dipchand Choksi and Other Shri Visha Shrimali Vidyotejak, Surat vs. CIT(Exemption), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 178/SRT/2025[NA]Status: DisposedITAT Surat29 Aug 2025

Bench: Dinesh Mohan Sinha & Shri Bijayananda Pruseth

Section 12ASection 80GSection 80G(5)Section 80G(5)(iii)

issued by the CIT(E), the assessee filed submission on 15.11.2024. He has discussed legal background of Rule 11AA(1), 11AA(2) and sections 2(15), 80G(5) along with Explanation – 3 and section 80G(5B). He subsequently issued a show cause notice dated 09.12.2024 and the assessee submitted

Kosuke Sports Foundation, Pune vs. DCIT, Exemption Circle, Pune

In the result, appeal” Unquote

ITA 1195/PUN/2025[2025-26]Status: DisposedITAT Pune29 Aug 2025AY 2025-26

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

Section 11Section 12Section 12ASection 12A(1)(ac)Section 8Section 80G

Commissioner of Income Tax (exemption) has to verify Objects of the trust, whether they are charitable or not as defined in section 2(15) of the Act, and Genuineness of Activities and whether the activities are as per the Objects or not. One more aspect the Commissioner of Income ... national and international tournaments 9.1 These are some of the objects of the Assessee. These Objects are charitable in nature as per the section 2(15) of the Act.Fencing is a combat sport that features sword fighting. Fencing is a Olympic sports since 1986. 10. Now, lets understand the activities

Kosuke Sports Foundation, Pune vs. DCIT, Exemption Circle, Pune

In the result, appeal” Unquote

ITA 1194/PUN/2025[2025-26]Status: DisposedITAT Pune29 Aug 2025AY 2025-26

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamore

Section 11Section 12Section 12ASection 12A(1)(ac)Section 8Section 80G

Jinseva Foundation, Mumbai vs. CIT (Exemption), Mumbai

In the result, both the appeals of the assessee are treated as allowed

ITA 3532/MUM/2025[2025-2026]Status: DisposedITAT Mumbai29 Aug 2025AY 2025-2026

Bench: Ms. Kavitha Rajagopal () & Smt. Renu Jauhri ()

For Appellant: Mr. Margav ShuklaFor Respondent: Mr. Vivek Perampurna, CIT-DR

Section 11Section 12ASection 8

granting registration u/s 12A of the Act. The scheme of the Act is that all entities carrying out charitable activities, as defined in section 2(15) of the Act, qualify to be registered as charitable entities subject to satisfaction of the concerned officer vis-a-vis their objects and activities

Jinseva Foundation, Mumbai vs. CIT (Exemption), Mumbai

In the result, both the appe

ITA 3531/MUM/2025[2025-2026]Status: DisposedITAT Mumbai29 Aug 2025AY 2025-2026

Bench: Ms. Kavitha Rajagopal () & Smt. Renu Jauhri ()

For Appellant: Mr. Margav Shukla

Section 11Section 12A

carrying out charitable activities, as defined Act. The scheme of the Act is that all entities carrying out charitable activities, as defined in section 2(15) of the Act, qualify to be registered as in section 2(15) of the Act, qualify to be registered as charitable entities subject

National Association for the Blind, Mumbai vs. CIT (Exemptions), Mumbai

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

ITA 2490/MUM/2025[2026-27]Status: DisposedITAT Mumbai29 Aug 2025AY 2026-27

Bench: Shri Narender Kumar Choudhry & Shri Omkareshwar Chidaraassessment Year: 2026-27

For Appellant: Ms. Jasmin Amalsadvala, Ld. A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Ld. D.R

Section 11Section 80GSection 80G(5)

Association [1980] 121 ITR l/[1980] 2 Taxman 501, where the speech made by the Finance Minister, while introducing the exclusionary clause in section 2(15) of the Act, was relied upon by the Court for the purpose of ascertaining what was the reason for introducing that clause

Sikh Missionarycollege, Ludhiana vs. Income Tax Office, Exmeption Ward, Jalandhar

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

ITA 640/ASR/2024[2023-24]Status: DisposedITAT Amritsar26 Aug 2025AY 2023-24

Bench: Shri Udayan Das Gupta & Shri Brajesh Kumar Singh[Assessment Year:2023-24]

Section 80GSection 80G(5)

evidence regarding the declaration that the activities are only charitable cannot be accepted. Thereafter, the ld. CIT(E) discussed about the provisions of section 2(15) of the Act and the relevant provisions of section 80G and also reproduced the decision of the Hon’ble Apex Court in the case

Shri Samarth Shravan Foundation, Pune vs. ITO, Exemption Ward 1(1), Pune

In the result, both the appeals of the Assessee are dismissed

ITA 2730/PUN/2024[-]Status: DisposedITAT Pune26 Aug 2025

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripote

Section 10Section 12ASection 8Section 80G

आयकरअपीलीयअिधकरण ”B” "ायपीठ पुणे म"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B” :: PUNE BEFORE MS. ASTHA CHANDRA, JUDICIAL

Shri Samrath Shravak Foudation, Pune vs. ITO Exemption Ward 1(1), Pune

In the result, both the appeals of the Assessee are dismissed

ITA 2729/PUN/2024[-]Status: DisposedITAT Pune26 Aug 2025

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripote

Section 10Section 12ASection 8Section 80G

आयकरअपीलीयअिधकरण ”B” "ायपीठ पुणे म"। IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B” :: PUNE BEFORE MS. ASTHA CHANDRA, JUDICIAL

(Tulsidham) Shree Shyam Pariwar, Kolkata vs. C.I.T.(Exemption), Kolkata

In the result, both the appeals of the assessee are allowed for statistical purposes

ITA 1125/KOL/2025[-]Status: DisposedITAT Kolkata25 Aug 2025

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 12A(1)(ac)Section 2(15)Section 80G(5)(iii)

which was carefully perused by the Ld. CIT( E) and thereafter asked the assessee to furnish the details of the donation undertaking for Section 2(15), 13(3) and 12AB(ii)and details of IDs of trustees etc. The assessee failed to submit any compliance and reply as a result

Madhav University, Pindwara, Sirohi vs. CIT(Exemption), Jaipur

In the result, both the appeals filed by the assessee bearing ITA No

ITA 789/JODH/2024[2024-25]Status: DisposedITAT Jodhpur22 Aug 2025AY 2024-25

Bench: Dr. Mitha Lal Meena, Hon'Ble & Shri Anikesh Banerjee, Hon'Bleι.Τ.Α No.789 &790/Jodh/2024 (Assessment Year:2024-25) Madhav University Vs Commissioner Of Income-Tax, Exemption, Jaipur Pindwara, Madhav Hills, Nh 27, Vpo Bharja, Pindwara, Sirohi Rajasthan-307023 Pan: Aasam7855L Shri Amit Kothari Shri M.K. Jain, Cit(Dr.) Present For Assessee Present For Revenue Date Of Hearing 20/08/2025 Date Of Pronouncement 22/08/2025 Order Per Bench: The Instant Appeals Of The Assessee Filed Against The Order Of The Learned Commissioner Of Income-Tax (Exemption), Jaipur (For Brevity, 'Ld.Cit(E)'] Order Passed Under Section 12Ab Of The Income-Tax Act, 1961 (In Short, 'The Act') & Order Passed Under Section 80G(5) Of The Act, Date Of Orders 30/09/2024. 2. Act Both The Appeals Related To Registration Under Section 12Ab& 80G Of The

Section 11Section 12ASection 3(2)Section 80Section 80G(5)

education, aligning with our charitable objective of promoting education. 4.13. Utilization of Surplus Reinvestment in Educational Purpose: As a charitable institution under Section 2(15), the university is committed to applying its funds solely for the advancement of education. The surplus generated during the financial years has been fully reinvested ... material on record in APB pages 10-84 shows that the assessee is engaged in charitable activities within the meaning of section 2(15) of the Act. On the issue of surplus generation, it is well settled by the Hon'ble Supreme Court in Queen's Educational Society(supra

Shree Balaji Sewa Trust, Prashant Vihar vs. CIT Exemption Delhi

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

ITA 5791/DEL/2024[2023-24]Status: DisposedITAT Delhi22 Aug 2025AY 2023-24

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Ved Mittal, AdvFor Respondent: Shri Manish Gupta, Sr. DR

Section 12ASection 80G

claim benefit under Sections 11 and 12 of the Act unless the case of assessee is specifically hit by the Proviso of Section 2(15) of the Act, which is not the case here. The Proviso to Section 2(15) of the Act would not get attracted merely

ACIT E Circle-1(1) New Delh, Delhi vs. Jeen Foundation, Delhi

In the result, the grounds raised by the revenue are accordingly dismissed

ITA 4118/DEL/2024[2018-19]Status: DisposedITAT Delhi22 Aug 2025AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Amit Kumar Jain, CIT DR

Section 11Section 12ASection 13(8)Section 142(1)Section 143(3)Section 2(15)Section 25

imparting education in the nature of Trade, Commerce and Business are distinct from the object of general public utility as specified under section 2(15) of the Act? 2. On the facts & in the circumstances of the case and in law, the learned CIT (A) has erred in allowing ... classification General Public Utility. He rejected the claim of the assessee and observed that for the purpose of GPU, the definition of section 2(15) of the Act makes the difference in claiming the exemption varies, accordingly asked for the various information vide notice

ACIT (E) Circle-1(1) New Dehi, Delhi vs. Jeen Foundation, Delhi

In the result, the grounds raised by the revenue are accordingly dismissed

ITA 4117/DEL/2024[2017-18]Status: DisposedITAT Delhi22 Aug 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Vimal Kumar

For Appellant: Shri K. Sampath, AdvocateFor Respondent: Shri Amit Kumar Jain, CIT DR

Section 11Section 12ASection 13(8)Section 142(1)Section 143(3)Section 2(15)Section 25

Mahathma Eye Vision and Research Institute, Tiruchirappalli vs. CIT, Exemptions, Chennai

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

ITA 157/CHNY/2025[-]Status: DisposedITAT Chennai21 Aug 2025

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

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT

Section 11Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(i)

आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी मनु कुमार

Mahatma Eye Vision and Research Institute, Tiruchirappalli vs. CIT, Exemptions, Chennai

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

ITA 1008/CHNY/2025[-]Status: DisposedITAT Chennai21 Aug 2025

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

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT

Section 11Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(i)

आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी मनु कुमार

Shri Sankat Mochan Balaji Mandal, New Delhi vs. CIT Exemptoin, Delhi

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

ITA 1910/DEL/2025[-]Status: DisposedITAT Delhi21 Aug 2025

Bench: MS. MADHUMITA ROY (Judicial Member), SHRI NAVEEN CHANDRA (Accountant Member)

Section 13(1)(c)Section 2(15)Section 80G(5)(iii)

ground of non-furnishing of certain documents. NOC from the owner of the premises from which the applicant operating charitable activity, undertaking under section 2(15) of the Act, Declaration under section 13(1)(c) of the Act, list of donors and the details of the donation received not provided