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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)

M/S. Crab Meat Processors Association, Tuticorin vs. CIT, Exemptions, Chennai

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

ITA 510/CHNY/2025[2021-22]Status: DisposedITAT Chennai20 Aug 2025AY 2021-22

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.510/Chny/2025 Assessment Years: 2021-22 M/S.Crab Meat Processors Association, Commissioner Of Income Tax No.18, Tuticorin Cooperative Industrial (Exemption), Estate Limited, Korampallam, Tuticorin, Chennai. Tamil Nadu-628 101. [Pan: Aacac8490R] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri D.Anand, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.E.Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 13.08.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri D.Anand, AdvocateFor Respondent: Ms.E.Pavuna Sundari, CIT
Section 11Section 12Section 12A

trust qua relief of poor, education, medical relief, preservation of environment cannot be concluded as falling under definition of charitable as defined in section 2(15) of the Act. A unilateral conclusion cannot be basis for a judicious decision. It is trite law that opportunity of being heard

Oriental Ardaas Foundation, New Delhi vs. CIT(Exemption), New Delhi

The appeals of the assessee are allowed

ITA 5079/DEL/2024[-]Status: DisposedITAT Delhi20 Aug 2025

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri KVSR Krishna, CAFor Respondent: Ms Amisha S. Gupt, CIT-DR
Section 12ASection 2(15)Section 80G

stated objectives and the intended activity of the applicant does not come under the purview of ‘charitable activity’ as per the provisions of section 2(15) of the Act. The relevant findings of competent authority are reproduced below; “3. On a perusal of the submissions, it is seen that

Oriental Ardaas Foundation, New Delhi vs. CIT(Exemption), New Delhi

The appeals of the assessee are allowed

ITA 5078/DEL/2024[-]Status: DisposedITAT Delhi20 Aug 2025

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri KVSR Krishna, CAFor Respondent: Ms Amisha S. Gupt, CIT-DR
Section 12ASection 2(15)Section 80G

stated objectives and the intended activity of the applicant does not come under the purview of ‘charitable activity’ as per the provisions of section 2(15) of the Act. The relevant findings of competent authority are reproduced below; “3. On a perusal of the submissions, it is seen that

Rajvee Foundation, Patan vs. The CIT(Exemption), Ahmedabad

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

ITA 438/AHD/2025[NA]Status: DisposedITAT Ahmedabad19 Aug 2025

Bench: Ms Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.438/Ahd/2025 िनधा"रण वष" /Assessment Year : N.A Rajvee Foundation, The Commissioner Of 8, Yash Kutir Society, बनाम/ Income Tax, V/S. Padamnath Chikadi, (Exemption), Patan-384265. Ahmedabad (Gujarat) "थायी लेखा सं./Pan: Aaetr6780Q अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Kunal P Sanghvi, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 14/08/2025 घोषणा की तारीख /Date Of Pronouncement: 19/08/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: ] ] This Appeal By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Exemption), Ahmedabad [Hereinafter Referred To As “Cit(E)”] Dated 26.12.2024, Passed Under Section 80G(5) Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], Whereby The Assessee’S Application In Form No. 10Ab For Approval Under Section 80G Was Rejected & The Provisional Approval Earlier Granted Was Cancelled. Rajvee Foundation Vs. Cit(E) Assessment Year N.A 2 Facts Of The Case

For Appellant: Shri Kunal P Sanghvi, ARFor Respondent: Shri Rignesh Das, CIT-DR
Section 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iii)

same set of facts. Registration under section 12AB is a foundational recognition that the institution exists for charitable purposes within the meaning of section 2(15) of the Act. Once such registration is granted, it is inconsistent and contradictory to deny approval under section 80G on the sole ground that

Mac Charities, Chennai vs. Commissioner of Income Tax (Appeals), New Delhi

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

ITA 2950/CHNY/2024[2020-21]Status: DisposedITAT Chennai19 Aug 2025AY 2020-21

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2950/Chny/2024 िनधा9रण वष9 /Assessment Year: 2020-21 Mac Charities, The Income Tax Officer, Mac Ich Building, Vhs Campus, Vs. Dlc-Ca-(201)(1), Ttti Post, Tharamani, Chennai. Chennai – 600 113. [Pan: Aaatm 0483F]

For Appellant: Shri R.Vijayaraghavan, AdvocateFor Respondent: Shri E.Pavuna Sundari, CIT
Section 11Section 11(5)Section 12ASection 133(6)Section 142(1)Section 143(3)Section 1lSection 2(15)

reason explaining the charitable nature of the business activities and how this business activity generating rental income does not violate the proviso of Section 2(15) of the Act, but the same was not satisfactorily explained. The A.O also issued notice u/s. 142(1) of the Act to support

Dasha Shrimali Kandoi Gnati, Rajkot vs. Commissioner of Income Tax (Exemption), Ahmedabad

The appeal of the assessee is allowed, for statistical purpose

ITA 96/RJT/2025[NA]Status: DisposedITAT Rajkot18 Aug 2025

Bench: Dr. Arjun Lal Saini & Shri Diesh Mohan Sinha

For Appellant: Shri Kamal Bhambhani, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. SR. DR
Section 12ASection 12A(1)Section 12A(1)(ac)Section 13Section 2(15)

benefit of public at large and the objects do not fall under the category of charitable objects as per the provisions of section 2(15) of the IT Act. the assessee submitted replay: “The objects of the trust are charitable for a particular cast, i.e. Dasha Shrimali Kandoi Ganti. However

Rajkot City Cyber Security Society, Rajkot vs. ITO WD 1(1)(1), RKT, Rajkot

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

ITA 265/RJT/2025[2024-25]Status: DisposedITAT Rajkot18 Aug 2025AY 2024-25

Bench: Dr. Arjun Lal Saini. & Shri Diesh Mohan Sinha

For Appellant: Shri Kaushal Dave, Ld. ARFor Respondent: ShriPraveen Verma, Ld. CIT(DR)
Section 12ASection 12A(1)(ac)Section 2(15)Section 80G

educational initiatives, conducting public seminars, collaborating with local authorities for cyber incident response, and supporting victims of cyber fraud or abuse. As per Section 2(15) of the Income-tax Act, 1961, "charitable purpose" includes relief of the poor, education, medical relief, and the advancement of any other object

Rotary Shaishnik Tabibi Seva Sahayak Mandal, Valsad vs. CIT(Exmeption), Ahmedabad

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

ITA 396/SRT/2025[NA]Status: DisposedITAT Surat18 Aug 2025

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकरअपीलसं./Ita No. 396/Srt/2025 (िनधा"रणवष" / Assessment Year: (Na) (Hybrid Hearing) Rotary Shaishnik Tabibi Seav Vs. Cit(Exemption) Sahayak Mandal Room No. 609, Floor No. 6, Ayakar Vai – Bhilad, At Post Sarigam Bhavan (Vejalpur), Prahalad Nagar, Road, Ahmedabad - 380015 Valsad – 396170 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahts6053N (Appellant) (Respondent) Appellant By : Shri Suresh K. Kabra, Ca Respondent By : Shri Ravi Kant Gupta, Ld.Cit(Dr) Date Of Hearing : 04/08/2025 Date Of Pronouncement : 18/08/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Suresh K. Kabra, CAFor Respondent: Shri Ravi kant Gupta, Ld.CIT(DR)
Section 12ASection 2(15)

violations of conditions specified under section 12AB(4) explanation clause(a) to clause(e), 13(1) clause (a) to (c). 1 proviso to section 2(15) or any action has been taken in your case by the department for any default under these provisions or any action has been taken

T vs. Charities, Maduraivs.ITO, Exemptions Ward, Madurai

In the result, appeal filed by the assessee is allowed

ITA 413/CHNY/2025[-]Status: DisposedITAT Chennai18 Aug 2025

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.413/Chny/2025 िनधा"रण वष"/Assessment Year: - V. Tvs Charities, The Ito, 7-B, Tvs Building West Veli Street, Exemptions Ward, Madurai-625 001. Madurai.

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

ought to have given an opportunity to the appellant to demonstrate why the case of the appellant falls within the definition of section 2(15). 3. The CIT failed to appreciate that all the particulars called for by him vide his notice dated 25.11.2024 were materials on record. Further details ... appellant's object did not fall within the meaning of education/medical/relief for poor and thus did not fall within the definition of section 2(15) of the Act. 7. Alternatively, the CIT erred in rejecting the contention of the appellant that its object falls under the limbs of advancement

Noida Golf Course Society, Noida vs. JCIT, Noida

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

ITA 2053/DEL/2015[2010-11]Status: DisposedITAT Delhi08 Aug 2025AY 2010-11

Bench: Shri M Balaganesh

For Appellant: Shri Rajiv Sharma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 11(1)Section 11(1)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)Section 2(15)Section 250

erred in law and on facts, While considering the Objectives of the Appellant as commercial , Whereas the Objectives are Charitable and covered under section 2(15) and Explained by us during the Course of our hearings. ITA Nos.2052 & 2053/Del/2017 6. BECAUSE the AO and the Ld CIT(A) had erred

Noida Golf Course Society, Noida vs. JCIT, Noida

ITA 2052/DEL/2015[2009-10]Status: DisposedITAT Delhi08 Aug 2025AY 2009-10

Bench: Shri M Balaganesh & Shri Vimal Kumar

For Appellant: Shri Rajiv Sharma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 11(1)Section 11(1)(c)Section 12ASection 142(1)Section 143(1)Section 143(2)Section 2(15)Section 250

erred in law and on facts, While considering the Objectives of the Appellant as commercial, Whereas the Objectives are Charitable and covered under section 2(15) and Explained by us during the Course of our hearings. 6. BECAUSE the AO and the Ld CIT(A) had erred

Assistant Commissioner of Income Tax (Central Circle), Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 620/LKW/2024[2016-17]Status: DisposedITAT Lucknow07 Aug 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

assessing officer has been satisfied that assessee is an charitable institute and its activities are charitable activities within the ambit of provisions of section 2(15) of Income Tax Act, 1961. 4.3 As regards the allegation of Ld. AO. that assessee has made contravention of provisions of section

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 619/LKW/2024[2015-16]Status: DisposedITAT Lucknow07 Aug 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

assessing officer has been satisfied that assessee is an charitable institute and its activities are charitable activities within the ambit of provisions of section 2(15) of Income Tax Act, 1961. 4.3 As regards the allegation of Ld. AO. that assessee has made contravention of provisions of section

Monkombu Aundi Iyer Educational and Charitable Trust, Idukki vs. The Commissioner of Income Tax Exemption, Kochi

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

ITA 911/COCH/2024[2025-2026]Status: DisposedITAT Cochin06 Aug 2025AY 2025-2026

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 11Section 11(5)Section 12ASection 13(1)(d)Section 2(15)Section 80G

trust undertakes any business activity, it shall comply strictly with the conditions laid down under section 11(4A) read with proviso to section 2(15). 3. Aggrieved by the above order assessee is in appeal before this tribunal at the time of hearing ld. AR stated that the impugned order

Bigala Krishna Murthy Foundation, Hyderabad vs. CIT (Exemption), Hyderabad

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

ITA 11/HYD/2025[2024-25]Status: DisposedITAT Hyderabad06 Aug 2025AY 2024-25

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.11/Hyd/2025 (निर्धारण वर्ा/Assessment Year:2024-25) M/S. Bigala Krishna Murthy Commissioner Of Income Tax Vs. (Exemption), Hyderabad. Foundation, Hyderabad. Pan:Aakcb1687M (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri M. Venkatram Reddy, Advocate रधजस् व द्वधरध/Revenue By:: Shri Narendra Kumar Naik, Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 30/07/2025 घोर्णध की तधरीख/Pronouncement: 06/08/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By M/S. Bigala Krishna Murthy Foundaton (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Exemptions), Hyderabad (“Ld. Cit(E)”), Dated 24.10.2024 For The A.Y. 2024-25. Ita No.11/Hyd/2025 2

For Appellant: Shri M. Venkatram ReddyFor Respondent: : Shri Narendra Kumar Naik
Section 11Section 12ASection 2(15)

Hence, the activities of the Appellant cannot be held to be Commercial in nature and are not in violation of the proviso to Section 2(15) of the Income Tax Act. 8. The Ld. CIT did not consider the following comparable institutes that have been registered and are listed

M/S. Innovative Micrfinance for Poverty Alleviation & Community Transformation, Chennai vs. CIT, Exemptions, Chennai

ITA 1161/CHNY/2025[-]Status: DisposedITAT Chennai06 Aug 2025

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1161/Chny/2025

Section 11Section 80G

आयकर अपीलीय अधिकरण, 'सी' न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI श्री एबी टी. वर्की, न्यायिक

Shiksha Bharti Educational Society, Haryana vs. CIT(Exemption), Chandigarh

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

ITA 5448/DEL/2024[-]Status: DisposedITAT Delhi06 Aug 2025

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Dhruv Goel, CAFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 12(1)(ac)Section 12ASection 12A(1)(aciii)Section 2(15)Section 80G

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN

Shiksha Bharti Educational Society, Haryana vs. CIT(Exemption), Chandigarh

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

ITA 5447/DEL/2024[-]Status: DisposedITAT Delhi06 Aug 2025

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Dhruv Goel, CAFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 12(1)(ac)Section 12ASection 12A(1)(aciii)Section 2(15)Section 80G

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN

Dr K R Shroff Foundation, Ahmedabad vs. The Dy. CIT, Circle-1, Exmp, Ahmedabad

Appeal of the assessee is partly allowed

ITA 769/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 147Section 68

Nos.1205 & 769/Ahd/2025 Assessment Years: 2018-19 ACIT(E) vs. Dr. KR Shroff Foundation Page 13 of 24 definition of ‘charitable purpose’ as per Section 2(15) of the Act. This apart, the Assessing Officer had given the following reasons for denying the exemption under Section ... observe that even if the assessee was not imparting any formal education, its activities were covered in the definition of ‘charitable purpose’ under Section 2(15) of the Act, as it was engaged in the activities of advancing of any other object of general public utility in the field

ACIT (Exemption) Circle 1 Ahmedabad, Ahmedabad vs. Dr K R Shroff Foundation, Ahmedabad

ITA 1205/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad05 Aug 2025AY 2018-19

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinha

Section 11Section 12ASection 143(3)Section 147Section 68

ITA Nos.1205 & 769/Ahd/2025 Assessment Years: 2018-19 ACIT(E) vs. Dr. KR Shroff Foundation Page 1 of 24 IN THE