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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)

Rkm Social Welfare Foundation, Chennai vs. CIT Exemption, Chennai

ITA 3233/CHNY/2024[2025-26]Status: DisposedITAT Chennai25 Jun 2025AY 2025-26

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 3233/Chny/2024 धनिाारण वर्ा / Assessment Year: 2025-26 Rkm Social Welfare Foundation, The Commissioner Of Income Tax (Exemption), 52/101, Chamiers Road, Vs. R.A. Puram, 121 Mahatma Gandhi Road Chennai – 600 028. Nungambakkam, Chennai. [Pan: Aakcr-3307-A] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. N.C. Ravi Krishnan, C.A. प्रत्यथी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit. सुनवाई की तारीख/Date Of Hearing : 25.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 11.08.2025

For Appellant: Shri. N.C. Ravi Krishnan, C.AFor Respondent: Shri. Shiva Srinivas, CIT
Section 12ASection 2(15)Section 8

seen that the applicant is not engaged in any charitable activities and its activities does not fall under any limb as defined in section 2(15) of the Income Tax Act 1961. For brevity the same is reproduced as under: The expression “charitable purpose” has been defined under Section 2 ... involve public benefit as to fall within the meaning of charitable object. Therefore, education to fall within the limb of "charitable purpose” under section 2(15) should be for advancement of public and not merely for few specific persons. 8. Since, the foundation is actually engaged itself as recruiting agency

Hapur Pilkhuwa Development Authority, Delhi vs. DCIT, Exemtion Circle, Ghaziabad

In the result, appeal filed by the Assessee stands allowed

ITA 4691/DEL/2024[2014-15]Status: DisposedITAT Delhi25 Jun 2025AY 2014-15

Bench: Shri Mahavir Singh, Vice Presdident & Shri Manish Agarwala.Yr. : 2014-15 Hapur Pilkhuwa Vs. Dcit Exemption Circle, Development Ghaziabad Authority, Room No. 105, Cgo C/O Kapil Goel, Complex, Advocate 1St Floor, Kamla Nehru F-26/124, Sector-7, Rohini, Nagar, Ghaziabad Delhi – 110 085 Uttar Pradesh (Pan: Aaalh0057L) (Appellant) (Respondent) Assessee By Dr. Kapil Goel, Adv. Department By Shri Surender Pal Singh, Cit(Dr) Date Of Hearing : 27.03.2025 Date Of Pronouncement : 25.06.2025 Order Per Mahavir Singh, Vp : This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.08.2024 Passed By The Nfac, New Delhi In Relation To Assessment Year 2014-15 On The Following Grounds:- I) That Orders Of Ao & Ld. First Appellate Authority Respectively Passed U/S. 143(3) & Section 250 Are Both Invalid / Nullity & Both Deserve To Be Quashed / Set Aside For Total Want Of Application Of Mind & Being Passed In Most 1

Section 11Section 12Section 12ASection 142(1)Section 143(2)Section 143(3)Section 143(34)Section 154Section 2(15)Section 250

section 250 are both invalid in so far as aspect of holding of assessee’s activities fall foul of section 2(15) of the Act (that is assessee’s activities are not charitable in nature u/s. 2(15) which is grossly perverse and patently illegal on face ... been held that “there is no good reason for holding that Statutory bodies could not be treated as charitable within the meaning of section 2(15) of the Act, as its object is to provide shelter to the homeless people. 11. So there being no material/evidence on record supporting

Sri Guru Trust, Cuttack vs. Commissioner of Income Tax (Exemption), Hyderabad

In the result, appeal of the assessee in ITA No

ITA 100/CTK/2025[2025-26]Status: DisposedITAT Cuttack24 Jun 2025AY 2025-26

Bench: The Commissioner Of Income Tax (Exemption), Hyderabad Vide Form 10Ab Vide Acknowledgement Number 419790920110624 Dated 11.06.2024 Submitting Other Documents Such As (1) Darpan Details (Ii) 80G Provisional Registration Certificate (Iii) Trust Deed (Iv) 12A Certificate (V) Financial Statements For Fy 19-20, 20- 21 & 21-22 & Activity Report. The Ld. Cit(E) Rejected The 80G Application Made By The Assessee Providing A Bald Statement Bereft Of Any Specific Findings That 'No Substantial Activities Which Are Charitable In Nature Are Being Carried Out By The Assessee, Which Is In Violation Of The Provisions Of The Section 80G Of The It Act, 1961'. It Was Submitted By The Id. Counsel For The Assessee That Once The Assessee Is Registered Under Section 12A Of The Act, The Application Filed By The Assessee Vide Form 10Ab For Approval U/S.80G Of The Act Deserves To Be Allowed. 5. On The Other Hand, Id. Cit-Dr Supported The Order Of The Id.Cit(E) & Submitted That The Assessee Trust Was Unable To Substantiate Before The Id. Cit(E) That Its Activities Are Charitable In Nature. Thus, The Id.Cit- Dr Prayed That The Order Passed By The Id. Cit(E) Should Be Upheld. 3

Section 12Section 12ASection 2(15)Section 80GSection 80G(5)(iii)

2 ITA No.91&100/CTK/2025 out any activities which are charitable in nature violating the provisions of Section 80G of the