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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)

Nathmal Jee Foundation, Jaipur vs. CIT (Exemption), Jaipur

ITA 76/JPR/2024[2023-24]Status: DisposedITAT Jaipur19 May 2025AY 2023-24

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Rajeev Sogani, CA, Ld. ARFor Respondent: Mr. Rajesh Ojha, CIT, Ld. DR
Section 11(1)Section 12ASection 2(15)Section 80GSection 80G(5)

came into existence on 12th April 2022. It is observed that the Ld. CIT (E), Jaipur primarily relied on the provisions of section 2(15) of the Act, which is reproduced below as under: (15) "Charitable purpose" includes relief of the poor, education, [yoga,] medical relief, preservation of environment(including ... Jaipur, it is observed that the findings of the Ld. CIT(E), Jaipur does not establish the applicability of the provisions of section 2(15) of the Act. 4. We have gone through the audited financials also of the assessee and it is observed that the assessee has a surplus

DCIT Exmp Circle Pune, Swargate Pmt Bldg vs. Ashirwad Charitable Trust, Mumbai

In the result, the appeal filed by the Revenue in ITA

ITA 225/PUN/2024[2014]Status: DisposedITAT Pune16 May 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

For Appellant: Shri Raja B. Singh &For Respondent: Shri Ramnath P. Murkunde
Section 11Section 12ASection 2(15)Section 3Section 5

raised the following grounds of appeal :- “1. On the facts and circumstance of the case, Ld. CIT(A) erred in interpreting the Section 2(15) of the Income Tax Act, 1961, in the Context of Charitable Activities and also in the context of the assessce Ashirwad Prayer Centre ... trust, involving the sale of CDs, DVDs, books and holy oil, coupled with substantial expenditure on advertising. contravene the provisions of section 2(15) of the Act by virtue of engaging in activities of a commercial, business or trade nature. 2. On facts and circumstance of the case, the activities

Dy Commissioner of Income Tax Exmp Circle Pune, Swargate Pmt Bldg vs. Ashriwad Charitable Trust, Mumbai

In the result, the appeal filed by the Revenue in ITA

ITA 224/PUN/2024[2014]Status: DisposedITAT Pune16 May 2025

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.224 & 225/Pun/2024 िनधा"रण वष" / Assessment Year : 2014-15 Dcit (Exemptions) Circle, Vs. Ashirwad Charitable Pune. Trust, 402, Pascal Martin Road, Regent Chambers, Nariman Point, Mumbai- 400021. Pan : Aabta4479Q Appellant Respondent Revenue By : Shri Ramnath P. Murkunde Assessee By : Shri Raja B. Singh & Mohd. Obaid Ansari Date Of Hearing : 18.02.2025 Date Of Pronouncement : 16.05.2025 आदेश / Order Per Vinay Bhamore, Jm: Both The Above Captioned Appeals Filed By The Revenue Are Directed Against The Separate Orders Dated 06.12.2023 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15 Respectively. 2. Since The Facts Are Identical & Both The Above Captioned Appeals Were Heard Together, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal In Ita No.224/Pun/2024 For Adjudication.

For Appellant: Shri Raja B. Singh &For Respondent: Shri Ramnath P. Murkunde
Section 11Section 12ASection 2(15)Section 3Section 5

raised the following grounds of appeal :- “1. On the facts and circumstance of the case, Ld. CIT(A) erred in interpreting the Section 2(15) of the Income Tax Act, 1961, in the Context of Charitable Activities and also in the context of the assessce Ashirwad Prayer Centre ... trust, involving the sale of CDs, DVDs, books and holy oil, coupled with substantial expenditure on advertising. contravene the provisions of section 2(15) of the Act by virtue of engaging in activities of a commercial, business or trade nature. 2. On facts and circumstance of the case, the activities

Society for Rural Improvement, Palakkad vs. ACIT, Exemption Circle, Palakkad

In the result, the appeals filed by the assessee are allowed

ITA 488/COCH/2024[2018-2019]Status: DisposedITAT Cochin14 May 2025AY 2018-2019

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Suresh Kumar C, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 147Section 2(15)Section 263

been categorically held that the micro financing activities carried on by the assessee, qualify as charitable activity under the first limb of section 2(15) of the Act. It is submitted that the above order of the Tribunal was confirmed by the Hon’ble Kerala High Court in ITA No.165

Society for Rural Improvement, Palakkad vs. ACIT, Exemption Circle, Kochi

In the result, the appeals filed by the assessee are allowed

ITA 487/COCH/2024[2016-2017]Status: DisposedITAT Cochin14 May 2025AY 2016-2017

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Suresh Kumar C, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 147Section 2(15)Section 263

been categorically held that the micro financing activities carried on by the assessee, qualify as charitable activity under the first limb of section 2(15) of the Act. It is submitted that the above order of the Tribunal was confirmed by the Hon’ble Kerala High Court in ITA No.165

Society for Rural Improvement, Palakkad vs. ACIT, Exemption Circle, Kochi

In the result, the appeals filed by the assessee are allowed

ITA 486/COCH/2024[2015-2016]Status: DisposedITAT Cochin14 May 2025AY 2015-2016

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Suresh Kumar C, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 147Section 2(15)Section 263

been categorically held that the micro financing activities carried on by the assessee, qualify as charitable activity under the first limb of section 2(15) of the Act. It is submitted that the above order of the Tribunal was confirmed by the Hon’ble Kerala High Court in ITA No.165

M/S Society for Rural Improvement, Palakkad vs. ACIT. Exemption Circle, Kochi

In the result, the appeals filed by the assessee are allowed

ITA 485/COCH/2024[2014-2015]Status: DisposedITAT Cochin14 May 2025AY 2014-2015

Bench: Shri George George K, Vice- & Shri Inturi Rama Rao

For Appellant: Sri.Suresh Kumar C, CAFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 147Section 2(15)Section 263

been categorically held that the micro financing activities carried on by the assessee, qualify as charitable activity under the first limb of section 2(15) of the Act. It is submitted that the above order of the Tribunal was confirmed by the Hon’ble Kerala High Court in ITA No.165

Matha Medical Centre Trust, Kanyakumari vs. CIT, Exemptions, Chennai

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

ITA 197/CHNY/2025[-]Status: DisposedITAT Chennai14 May 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:197/Chny/2025 Matha Medical Centre Trust, Cit (Exemption), Moonkivilai, Vs. Chennai. Kalpadi Post, Kalkulam Taluk, Kanyakumari District – 629 204. [Pan: Aaatm-2246-C] (अपीलाथ"/Appellant) (""थ"/Respondent)

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. R. Clement Ramesh Kumar, C.I.T
Section 12ASection 2(15)Section 80G

failed to appreciate that the appellant trust was formed only to provide medical relief, hence, it falls under 1st six limbs of the Section 2(15) of IT Act 1961 and falls under "per se category". 3. The CIT (E) has failed to appreciate the Department Circular No.11 of CBDT ... 15) "it applied to the entity who pursue the advancement of any other public utility and not to that 1st 6 limbs of Section 2(15) ". 4. The ld.CIT(E) has also failed to appreciate that the appellant trust does not fall under the General Public Utility but clearly falls

Sawani Foundation Trust, Surat vs. CIT(Exemption), Ahmedabad

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

ITA 1276/SRT/2024[NA]Status: DisposedITAT Surat13 May 2025

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1248/Srt/2024 (Physical Hearing) Shree Mahavideh Charitable Vs. The Cit(Exemption), Trust, Ahmedabad 0/B/4, Tribhuvan Complex, Ghod Dod Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abdts9848Q (अपीलाथ"/Appellant) (""थ" /Respondent)

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

Rule 11AA(1), 11AA(2), section 80G(5) along with Explanation – 3 and Provision of sub-section (5B) introduced w.e.f. 01.04.2000 and section 2(15) of the Act. He noted that the date of application for registration for approval in Form No.10AB was 27.04.2024 and the date of provisional approval

Shree Mahavideh Charitable Trust, Surat vs. CIT(Exemption), Ahmedabad

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

ITA 1248/SRT/2024[NA]Status: DisposedITAT Surat13 May 2025

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1248/Srt/2024 (Physical Hearing) Shree Mahavideh Charitable Vs. The Cit(Exemption), Trust, Ahmedabad 0/B/4, Tribhuvan Complex, Ghod Dod Road, Surat - 395007 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abdts9848Q (अपीलाथ"/Appellant) (""थ" /Respondent)

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

Rule 11AA(1), 11AA(2), section 80G(5) along with Explanation – 3 and Provision of sub-section (5B) introduced w.e.f. 01.04.2000 and section 2(15) of the Act. He noted that the date of application for registration for approval in Form No.10AB was 27.04.2024 and the date of provisional approval

Icon Foundation, Jaipur vs. CIT Exemption, Jaipur

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

ITA 159/JPR/2025[2025-26]Status: DisposedITAT Jaipur13 May 2025AY 2025-26
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

failed to appreciate that the objects and activities of the appellant are wholly charitable and are in complete alignment with the provisions of section 2(15) of the Income Tax Act, which defines "charitable purpose" to include relief of the poor, education, and medical relief. The appellant's activities fall

Icon Foundation, Jaipur vs. CIT Exemption, Jaipur

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

ITA 158/JPR/2025[2025-26]Status: DisposedITAT Jaipur13 May 2025AY 2025-26
For Appellant: Shri Tarun Mittal, C.AFor Respondent: Shri Arvind Kumar, CIT-DR
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

failed to appreciate that the objects and activities of the appellant are wholly charitable and are in complete alignment with the provisions of section 2(15) of the Income Tax Act, which defines "charitable purpose" to include relief of the poor, education, and medical relief. The appellant's activities fall

Wevysya, Bengaluru vs. CIT(Exemptions), Bengaluru

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

ITA 106/BANG/2025[NA]Status: DisposedITAT Bangalore13 May 2025

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Dr. N Suresh, C.AFor Respondent: Shri Aseem Sharma, CIT (DR)
Section 12A

reflected from the trust’s objects and initial activities. The relevant headnotes of the judgment are as detailed under; “Section 12A, read with sections 2(15),11 and 12, of the Income- tax Act, 1961 - Charitable or religious trust - Registration of - Whether so long as a trust has education ... objects which is one of enumerated heads which qualifies and comes within scope of charitable purpose as enumerated in section 2(15), it has to be accepted that trust is having a charitable purpose as its object and may qualify for claiming exemption in terms of sections

Wevysya, Bengaluru vs. CIT(Exemptions), Bengaluru

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

ITA 105/BANG/2025[NA]Status: DisposedITAT Bangalore13 May 2025

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Dr. N Suresh, C.AFor Respondent: Shri Aseem Sharma, CIT (DR)
Section 12A

reflected from the trust’s objects and initial activities. The relevant headnotes of the judgment are as detailed under; “Section 12A, read with sections 2(15),11 and 12, of the Income- tax Act, 1961 - Charitable or religious trust - Registration of - Whether so long as a trust has education ... objects which is one of enumerated heads which qualifies and comes within scope of charitable purpose as enumerated in section 2(15), it has to be accepted that trust is having a charitable purpose as its object and may qualify for claiming exemption in terms of sections

Shri Siwanchi Oswal Jain Bhavan Trust, Bangalore vs. Commissioner of Income Tax, Exemptions, Bangalore

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

ITA 2173/BANG/2024[2024-25]Status: DisposedITAT Bangalore13 May 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Smt. Suman Lunkar, C.AFor Respondent: Shri Aseem Sharma, CIT (DR)
Section 12A

reflected from the trust’s objects and initial activities. The relevant headnotes of the judgment are detailed as under: “Section 12A, read with sections 2(15),11 and 12, of the Income- tax Act, 1961 - Charitable or religious trust - Registration of - Whether so long as a trust has education ... objects which is one of enumerated heads which qualifies and comes within scope of charitable purpose as enumerated in section 2(15), it has to be accepted that trust is having a charitable purpose as its object and may qualify for claiming exemption in terms of sections

Shri Siwanchi Oswal Jain Bhavan Trust, Bangalore vs. Commissioner of Income Tax, Exemptions, Bangalore

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

ITA 2172/BANG/2024[2024-25]Status: DisposedITAT Bangalore13 May 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Smt. Suman Lunkar, C.AFor Respondent: Shri Aseem Sharma, CIT (DR)
Section 12A

reflected from the trust’s objects and initial activities. The relevant headnotes of the judgment are detailed as under: “Section 12A, read with sections 2(15),11 and 12, of the Income- tax Act, 1961 - Charitable or religious trust - Registration of - Whether so long as a trust has education ... objects which is one of enumerated heads which qualifies and comes within scope of charitable purpose as enumerated in section 2(15), it has to be accepted that trust is having a charitable purpose as its object and may qualify for claiming exemption in terms of sections

Young Womens Christian Association, Thiruvananthapuram vs. Office of the Income Tax Officer, Expemtion Ward, Tvm, Thiruvanathapuram

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

ITA 274/COCH/2025[2016-17]Status: DisposedITAT Cochin08 May 2025AY 2016-17

Bench: Shri Inturi Rama Rao

For Appellant: --- None ---For Respondent: Smt.Leena Lal, Senior AR
Section 11Section 12ASection 143(3)Section 2(15)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, COCHIN Before Shri Inturi Rama Rao, Accountant Member ITA No.274/Coch/2025 : Asst.Year 2016

Jamshedpur Management Association, Jamshedpur vs. Commissioner of Income Tax Exemption, Patna

In the result, grounds of appeals raised by the assessee are allowed for statistical purposes only

ITA 157/RAN/2023[2022-23]Status: DisposedITAT Ranchi06 May 2025AY 2022-23

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Jamshedpur Management Association, C.I.T.(Exemption), 18, Centre For Excellence, Ch Area Patna Vs. (East), Jamshedpur-831001 (Jharkhand) Pan No. Aaeaj 2108 F Appellant/ Assessee Respondent/ Revenue

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

Institute. 3. That, the learned Commissioner of Income Tax (Exemption) erred in rejecting the application for registration u/s 12AA in applying proviso to Section 2(15) of the Income Tax Act while all the receipts are for the education purpose. 4. On the facts and circumstances of the case ... journals and periodicals. And to meet these objects fees has been charged from sponsoring entity and thus receipts do not attract proviso of Section 2(15). 6. On the facts and circumstances of the case, the learned Commissioner of Income Tax (Exemption) erred in rejecting the application for registration

Hare Krishna Movement Kota, Kota vs. CIT Exemption, Jaipur

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

ITA 211/JPR/2025[2023-24]Status: DisposedITAT Jaipur06 May 2025AY 2023-24

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No.211&210/JPR/2025 U/s 12AB and 80G of the Act निर्धारणवर्ष / AssessmentYear : 2023-24 Hare Krishna Movement Plot No. 14, OCF, NH 27, Mukundra Vihar Kota - 324 007 बनाम | The CIT-Exemption, Vs. Jaipur. प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: ACBAS 3236 L अपीलार्थी / Appellant निर्धारिती की ओरसे / Assesseeby : ShriAnoop Bhatia, CA राजस्व की ओरसे /Revenue by: Shri Rajesh Ojha, C

For Appellant: ShriAnoop Bhatia, CAFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 12ASection 80G

their resources are generally intended to be used exclusively for those purposes. Thus, these objects are not charitable in the light of section 2(15) of the Income Tax act. Supreme Court in its decision in the case of ACIT(Exemptions) versus Ahmedabad HARE KRISHNA MOVEMENT VS CIT (E), JAIPUR ... impugned objects are business activities as discussed in 2.1 above, these objects cannot be held as charitable within the meaning of section 2(15) of the Income Tax Act, 1961 and hence, the application of the applicant for registration u/s 12A is liable to be rejected In view

Hare Krishna Movement Kota, Kota vs. CIT Exemption, Jaipur

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

ITA 210/JPR/2025[2023-24]Status: DisposedITAT Jaipur06 May 2025AY 2023-24

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: ShriAnoop Bhatia, CAFor Respondent: Shri Rajesh Ojha, CIT-DR
Section 12ASection 80G

their resources are generally intended to be used exclusively for those purposes. Thus, these objects are not charitable in the light of section 2(15) of the Income Tax act. Supreme Court in its decision in the case of ACIT(Exemptions) versus Ahmedabad HARE KRISHNA MOVEMENT VS CIT (E), JAIPUR ... impugned objects are business activities as discussed in 2.1 above, these objects cannot be held as charitable within the meaning of section 2(15) of the Income Tax Act, 1961 and hence, the application of the applicant for registration u/s 12A is liable to be rejected In view