Section 2(15) — 1,405 case laws

Yakshit Yuva Foundation, Belagavi vs. CIT (Exemption), Bengalore

Appeals stands Allowed

ITA 233/PAN/2025[12AB]Status: DisposedITAT Panaji06 Mar 2026

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 233 & 234/Pan/2025 Yakshit Yuva Foundation O/O Taekwondo Master Rao, 1St Fl, Gadekar Complex, P B Road, Kakati S.O., Belagavi. Pan : Aaaty9435D . . . . . . . Appellant V/S The Commissioner Of Income Tax, Exemption, Bangalore. . . . . . . . Respondent

For Appellant: Mr Shreepada Ravi Rao [‘Ld. AR’]For Respondent: Mr Azar Zain [‘Ld. DR’]

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

application was time barred and (ii) the predominant activity of providing training does not constitute a ‘charitable purpose’ within the meaning of section 2(15) of the Act and thus denied to grant regular registration u/s 12AB of the Act. ITAT-Panaji Page 3 of 22 Yakshit Yuva Foundation ... conclusion that, the appellant’s activities of providing ‘taekwondo training’ does not fall within the scope of charitable activities as defined in section 2(15) of the Act. In the course of hearing the Ld. DR Mr Zain while relying on the impugned order bottled-up the denial by adding

Sri Gaura Nitai Seva Trust, North Masi Street, Madurai vs. Income Tax Officer, Exemptions Ward, Income Tax Office, Madurai

In the result, appeal filed by the assessee is partly allowed

ITA 2130/CHNY/2024[2017-18]Status: DisposedITAT Chennai05 Mar 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Inturi Rama Rao

For Appellant: Shri N. Madan Kumar, JCITFor Respondent: 24.02.2026

Section 11Section 12ASection 143(3)Section 2(15)

while doing so the Assessing Officer had denied exemption u/s 11 of the Act by invoking the proviso to section 2(15) of the Act. The Assessing Officer of the opinion that the appellant trust was carrying on :- 3 -: activity in the nature of trade of commerce business ... appellant is in the nature of charitable activities. The appellant trust is indulging into trade and upheld the applicability of proviso to section 2(15) of the Act. 6. Being aggrieved the appellant is in appeal before us. In the present appeal, ld. Counsel for the appellant submitted that

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner Income Tax, Exemptions, Circle-1, Bangalore

ITA 355/BANG/2024[2017-18]Status: DisposedITAT Bangalore02 Mar 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

carried on by the appellant are commercial in nature intending to make profits. (b) concluding that appellant is hit by the proviso to section 2(15) r.w.s. 13(8). (c) not appreciating that the appellant, a statutory body of Government of Karnataka is a special entity to achieve the objectives ... claimed exemption under section 11 of the Act. 3.5 On facts and in the circumstances of the case and law applicable, proviso to section 2(15) and section 13(8) are inapplicable and the appellant is a genuine charitable organization. Consequently, exemption under section 11 is to be allowed

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner of Income-Tax, Exemptions, Circle-1, Bangalore

ITA 354/BANG/2024[2016-17]Status: DisposedITAT Bangalore02 Mar 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT-DR

Section 11Section 11(1)Section 13(8)Section 143(3)Section 153(1)Section 2(15)Section 250Section 43B

carried on by the appellant are commercial in nature intending to make profits. (b) concluding that appellant is hit by the proviso to section 2(15) r.w.s. 13(8). (c) not appreciating that the appellant, a statutory body of Government of Karnataka is a special entity to achieve the objectives ... claimed exemption under section 11 of the Act. 3.5 On facts and in the circumstances of the case and law applicable, proviso to section 2(15) and section 13(8) are inapplicable and the appellant is a genuine charitable organization. Consequently, exemption under section 11 is to be allowed

Deputy Commissioner of Income Tax (Exemptions), Vijayawada vs. Visakhapatnam Urban Development Authority, Visakhapatnam

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

ITA 742/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam27 Feb 2026AY 2016-17

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member)

Section 11Section 12ASection 143(3)Section 2(15)

mischief of “cess, or fee, or any other consideration” towards “trade, commerce or business”. Further, Section 11(4A) must be interpreted harmoniously with Section 2(15), with which there is no conflict. Carrying out activity in the nature of trade, commerce or business, or service in relation to such activities ... maintaining separate books of account is also in line with the necessity of demonstrating that the quantitative limit prescribed in the proviso to Section 2(15), has not been breached. The assessing authorities must every year, scrutinize the record to discern whether the nature of the assessee’s activities amounts

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

ITA 2750/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATΑ ‘Β' ΒENCH AT KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

ITA 2749/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATΑ ‘Β' ΒENCH AT KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

In the result, all the 3 appeals filed by the Assessee are partly

ITA 2748/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

been engaged in the activity of running a co- educational school for past many years. The definition of charitable activity as mentioned in section 2(15) of the Income Tax Act. 1961, also covers the education as a separate limb, and therefore the appellant qualifies this test as given ... time of assessment proceedings, its objectives and activities were clearly covered under the definition of charitable activities as per the section 2(15) of the Income Tax Act, 1961. (b) The appellant has also tried to demonstrate through its Income and Expenditure statement, that it has complied with the requirement

Kalabharti Charitable Foundation, Vadodara vs. CIT(Exemption), Ahmedabad

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

ITA 225/AHD/2025[N.A.]Status: DisposedITAT Ahmedabad25 Feb 2026

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Sunil Talati, CAFor Respondent: Shri R P Rastogi, CIT-DR

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

charitable purpose” for the purposes of section 80G of the Act. The CIT (Exemptions) placed reliance on the definition of “charitable purpose” under section 2(15) of the Act and on Explanation 3 to section 80G of the Act, as well as on the judgment of the Hon’ble Supreme

Ullal Charitable Trust, Mangalore vs. Commissioner of Income Tax(Exemptions), Bengaluru

In the result, the appeal filed by the assessee is allowed

ITA 1379/BANG/2025[2025-26]Status: DisposedITAT Bangalore25 Feb 2026AY 2025-26

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2025-26

For Appellant: Dr. Sheetal Borker, AdvocateFor Respondent: Shri Muthu Shankar, CIT-DR

Section 11(1)Section 11(1)(a)Section 12ASection 2(15)Section 80GSection 80G(5)(iii)

erred in holding that the appellant had not furnished sufficient details or proof of the activities of the trust/Institution within the meaning of section 2(15) of the Page 2 of 7 Income tax Act, 1961 when on the same set of facts and material furnished the learned ... submitted that the assessee had furnished several details or proof of the activities and therefore they are doing the charitable activities as per section 2(15) of the Act. The Ld.AR further submitted that simply because the assessee had received the fees receipts, along with the other donations, the provisions

Dolphin Club, Chennai vs. CIT Exemptions, Chennai

The appeal of the assessee is allowed

ITA 3107/CHNY/2024[-]Status: DisposedITAT Chennai23 Feb 2026

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं. Ita No 3107/Chny/2024 "नधा"रणवष"/Assessment Years: -- Dolphin Club V. Cit, (E), 3/15, Jeswanth Nagar, Mogappiar No. 121, Mahatma Gandhi West,Chennai-600037 Road, Nungambakkam Chennai-600034 [Pan: Aaatd 0288 P] (अपीलाथ"/Assessee) (""यथ"/Respondent)

For Respondent: Mr. Shiva Srinivas, CIT

Section 10Section 12ASection 12A(1)(ac)Section 2(15)

Exemptions), Chennai failed to appreciate that the activities pursued by the appellant entity would fall within the scope of the "education" limb in Section 2(15) of the Act inasmuch ought to have appreciated that the nature of scholastic instruction rendered by the appellant with the approval of another wing ... case for AY 2009–10, wherein it was held that the trust fell within the scope of “education” under the first limb of section 2(15) of the Income Tax Act, 1961. However, the factual basis for that conclusion has now lost relevance in view of the Hon’ble Supreme

Income Tax Officer (Exemption), Ward-Surat, Surat vs. Abhyuththan Gram Vikas Mandal, Surat

In the result, the appeal of the assessee and the Revenue, both are dismissed

ITA 902/SRT/2025[2018-19]Status: DisposedITAT Surat19 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 11Section 11(1)Section 13(1)(c)Section 194CSection 2(15)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE, JUDICIAL MEMBER

Abhyuththan Gram Vikas Mandal, Surat vs. CIT Exemption, Ahmedabad

In the result, the appeal of the assessee and the Revenue, both are dismissed

ITA 838/SRT/2025[2018-19]Status: DisposedITAT Surat19 Feb 2026AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms. Suchitra Kamble

Section 11Section 11(1)Section 13(1)(c)Section 194CSection 2(15)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT MS. SUCHITRA KAMBLE, JUDICIAL MEMBER

NA vs. Arjab Foundation Daisar, Patanvs.the CIT(Exemption), Ahmedabad

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

ITA 2635/AHD/2025[NA]Status: DisposedITAT Ahmedabad19 Feb 2026

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Gaurav Mehta, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 2(15)Section 35

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

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

ITA 653/RPR/2025[2017-18]Status: DisposedITAT Raipur17 Feb 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR

Section 11Section 12ASection 250

erred in making addition of Rs.1,71,93,880/- being net surplus shown in the income expenditure a/c on account of proviso to section 2(15) stating the activity of the assessee is in the nature of commercial activity and the receipts in the nature of commercial activity are more ... activity of the appellant during A.Y. 2011-12 in the nature of trade, commerce or business, the AO invoked the provision of section 2(15) of the Act and treated the net surplus of Rs. 1,71,93,880/- shown in income & expenditure statement and income earned by the appellant

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

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

ITA 652/RPR/2025[2016-17]Status: DisposedITAT Raipur17 Feb 2026AY 2016-17

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR

Section 11Section 12ASection 250

erred in making addition of Rs.1,71,93,880/- being net surplus shown in the income expenditure a/c on account of proviso to section 2(15) stating the activity of the assessee is in the nature of commercial activity and the receipts in the nature of commercial activity are more ... activity of the appellant during A.Y. 2011-12 in the nature of trade, commerce or business, the AO invoked the provision of section 2(15) of the Act and treated the net surplus of Rs. 1,71,93,880/- shown in income & expenditure statement and income earned by the appellant

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

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

ITA 651/RPR/2025[2013-14]Status: DisposedITAT Raipur17 Feb 2026AY 2013-14

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR

Section 11Section 12ASection 250

erred in making addition of Rs.1,71,93,880/- being net surplus shown in the income expenditure a/c on account of proviso to section 2(15) stating the activity of the assessee is in the nature of commercial activity and the receipts in the nature of commercial activity are more ... activity of the appellant during A.Y. 2011-12 in the nature of trade, commerce or business, the AO invoked the provision of section 2(15) of the Act and treated the net surplus of Rs. 1,71,93,880/- shown in income & expenditure statement and income earned by the appellant

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

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

ITA 650/RPR/2025[2012-13]Status: DisposedITAT Raipur17 Feb 2026AY 2012-13

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR

Section 11Section 12ASection 250

erred in making addition of Rs.1,71,93,880/- being net surplus shown in the income expenditure a/c on account of proviso to section 2(15) stating the activity of the assessee is in the nature of commercial activity and the receipts in the nature of commercial activity are more ... activity of the appellant during A.Y. 2011-12 in the nature of trade, commerce or business, the AO invoked the provision of section 2(15) of the Act and treated the net surplus of Rs. 1,71,93,880/- shown in income & expenditure statement and income earned by the appellant

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

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

ITA 649/RPR/2025[2011-12]Status: DisposedITAT Raipur17 Feb 2026AY 2011-12

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita Nos: 649, 650, 651, 652 & 653/Rpr/2025 (िनधा"रण वष" Assessment Years: 2011-12, 2012-13, 2013-14, 2016-17 & 2017-18) Chhattisgarh Housing Board, Vs Assistant Commissioner Of Income Sector-19, Paryavaas Bhawan, Tax (Exemption) Circle, Income Tax Naya Raipur, Chhattisgarh, 492002 Office, Quarter No.1, Type-V, Income Tax Residential Colony, Civil Lines, Raipur, Chhattisgarh, 492001 Pan: Aaeca9783D (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : Shri Shubham Mehta, Ca राज" की ओर से / Revenue By : Shri Raj Kumar Ghosh, Cit-Dr Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 11/02/2026 घोषणा की तारीख / Date Of : 17/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: Common Facts & Similar Grounds Arise In The Above Captioned Appeals Of The Assessee; Therefore, These Appeals Were Heard Together & Are Being Disposed Off By This Common Order.

For Appellant: Shri Shubham Mehta, CAFor Respondent: Shri Raj Kumar Ghosh, CIT-DR

Section 11Section 12ASection 250

erred in making addition of Rs.1,71,93,880/- being net surplus shown in the income expenditure a/c on account of proviso to section 2(15) stating the activity of the assessee is in the nature of commercial activity and the receipts in the nature of commercial activity are more ... activity of the appellant during A.Y. 2011-12 in the nature of trade, commerce or business, the AO invoked the provision of section 2(15) of the Act and treated the net surplus of Rs. 1,71,93,880/- shown in income & expenditure statement and income earned by the appellant

Charotar Bhal Rize Foundation, Ahmedabad vs. The CIT(Exemption), Ahmedabad

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

ITA 704/AHD/2025[NA]Status: DisposedITAT Ahmedabad17 Feb 2026

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Shri Mehul K. Patel, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iv)

held that the assessee had failed to substantiate its claim that the rice mill activity was charitable in nature within the meaning of section 2(15) of the Act, as no comparative rate charts or documentary evidence were furnished to show that the charges were substantially lower than those ... assessee had claimed advancement of “any other object of general public utility” as one of its objects. Referring to the proviso to section 2(15) of the Act, CIT(Exemptions) held that where such advancement involves carrying on activities in the nature of trade, commerce or business

“Section 2(15)”

Leading authorities on Section 2(15)

Judgments citing Section 2(15)

Yakshit Yuva Foundation, Belagavi vs. CIT (Exemption), Bengalore

Sri Gaura Nitai Seva Trust, North Masi Street, Madurai vs. Income Tax Officer, Exemptions Ward, Income Tax Office, Madurai

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner Income Tax, Exemptions, Circle-1, Bangalore

Karnataka Industrial Areas Development Board, Bangalore vs. Deputy Commissioner of Income-Tax, Exemptions, Circle-1, Bangalore

Deputy Commissioner of Income Tax (Exemptions), Vijayawada vs. Visakhapatnam Urban Development Authority, Visakhapatnam

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

Kalabharti Charitable Foundation, Vadodara vs. CIT(Exemption), Ahmedabad

Ullal Charitable Trust, Mangalore vs. Commissioner of Income Tax(Exemptions), Bengaluru

Dolphin Club, Chennai vs. CIT Exemptions, Chennai

Income Tax Officer (Exemption), Ward-Surat, Surat vs. Abhyuththan Gram Vikas Mandal, Surat

Abhyuththan Gram Vikas Mandal, Surat vs. CIT Exemption, Ahmedabad

NA vs. Arjab Foundation Daisar, Patanvs.the CIT(Exemption), Ahmedabad

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

Chhattisgarh Housing Board, Raipur vs. Exemption Circle, Raipur

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

Chhattisgarh Housing Board, Raipur vs. Assistant Commissioner, Exemption Circle, Raipur

Charotar Bhal Rize Foundation, Ahmedabad vs. The CIT(Exemption), Ahmedabad