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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)

The Icfai Society, Hyderabad vs. Assistant Commissioner of Income Tax (Exemptions), Circle-1(1), Hyderabad

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

ITA 661/HYD/2023[2015-16]Status: DisposedITAT Hyderabad30 Aug 2024AY 2015-16

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2015-16 The Icfai Society, Vs. The Assistant Commissioner Of Income Tax, Hyderabad. (Exemptions), Hyderabad. Pan : Aaajt0214B. (Appellant) (Respondent) Assessee By: Shri S. Ramarao, Advocate. (Appeared Through Virtual Mode) Revenue By: Smt. Th Vijaya Lakshmi, Cit-Dr Date Of Hearing: 30.07.2024 30.07.2024 Date Of Pronouncement:

For Appellant: Shri S. Ramarao, AdvocateFor Respondent: Smt. TH Vijaya Lakshmi, CIT-DR
Section 10Section 11Section 12ASection 13(8)Section 143(2)Section 154Section 2(15)

dominant profit motive. 2. That the order of the AO and the CIT (A) is bad in law and facts in applying section 2(15) read with section 13(8). 3. That the order of the AO and the CIT (A) is bad in law and facts in misinterpreting

Deputy Commissioner of Income Tax, Exemptions Circle, Chennai, Income Tax Department vs. The Indian Institute of Engineering Technology, Chennai

In the result the appeal of the Revenue dismissed

ITA 679/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 Aug 2024AY 2012-13

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.679/Chny/2024 िनधा;रण वष; /Assessment Year: 2012-13 The Dy. Commissioner Of The Indian Institute Of Engineering Income Tax, Vs. Technology, Exemptions Circle, 363, Arcot Road, Kodambakkam, Chennai. Chennai – 600 024. [Pan: Aaatt 2768C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथH की ओर से/ Assessee By : Shri R. Vijayaraghavan, Advocate JkथH की ओर से /Revenue By : Shri N. Sanjay Gandhi, Jcit सुनवाई की तारीख/Date Of Hearing : 11.06.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Revenue Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), (Nfac), Delhi [Hereinafter “Cit(A)] In Din & Order No.Itba/Nfac/S/250/2023- 24/1059500064(1), Dated 09.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2012-13 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 20.03.2015. :- 2 -: 2. There Is A Delay Of 06 Days In Filing The Appeal By The Revenue.

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Shri N. Sanjay Gandhi, JCIT
Section 10Section 11Section 12ASection 13(1)Section 13(1)(c)Section 13(1)(d)Section 143(3)

activities as a profitable venture , the A O held that the assessee is not undertaking any charitable activity within the scope of section 2(15) of the Act . Therefore, he denied the assessee’s exemption claim u/s 11, supra. It appears that this finding is not challenged by the assessee ... considered as existing for purposes of profit , its claim u/s 11 that it is existing for “charitable purposes” within the scope of section 2 (15) of the Act also fails both the ays . Thus, when the assessee is not entitled for the benefit u/s 11, all its other claims

DCIT(E) Circle-1(1), New Delhi, Civic Centre Delhi vs. Indian Olympic Association, Delhi

In the result, as the grounds have no substance the appeal of the Revenue is dismissed

ITA 2676/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Dr. B.R.R. Kumar & Shri Anubhav Sharmaassessment Year: 2017-18 Dcit (E), Vs Indian Olympic Association, Circle-1(1), Olympic Bhawan, New Delhi. B-29, Qutub Institutional Area, Delhi – 110 016. Pan: Aaati3010J (Appellant) (Respondent) Assessee By : Shri Nirbhay Mehta, Advocate Revenue By : Ms Parul Singh, Sr. Dr Date Of Hearing : 19.06.2024 Date Of Pronouncement : 30.08.2024

For Appellant: Shri Nirbhay Mehta, AdvocateFor Respondent: Ms Parul Singh, Sr. DR
Section 11Section 12ASection 143(3)Section 2(15)

such grants. The assessee claimed benefits of exemption u/s 11/12 of the Act as its objects and activities fall within the meaning of section 2(15) of the Act for the year under consideration. During the year under consideration, the assessee had entered into some sponsorship agreements with few Indian ... kinds of receipts and concluded that the activities of the assessee do not fall under the limbs of amended proviso to section 2(15) and has to be considered falling in the category of advancement of general public utility. The AO observed that the activities are commercial in nature

Dy. Commissioner of Income Tax(Exemptions)-2(1), Mumbai vs. Society for Applied Microwave Electronics Engineering and Research, Mumbai

In the result, the appeal of the revenue is dismissed

ITA 1132/MUM/2024[2013-14]Status: DisposedITAT Mumbai28 Aug 2024AY 2013-14

Bench: Shri Amit Shukla & Shri Ratnesh Nandan Sahayassessment Year: 2013-14 Dy. Commissioner Of Society For Applied Income Tax Microwave Electronics (Exemption)- 2(1) Engineering & Room No. 608, Research 6Th Floor, Sameer, Mtnl, Vs. Iit Campus, Peddar Road, Hill Side, Cumbala Hill, Mumbai- 400076. Maharashtra – 400026. Pan: Aalas5825K (Appellant) (Respondent)

For Appellant: Ms. Ritu Pujabi, A.RFor Respondent: Shri S. Srinivasu, CIT- D.R
Section 10(21)Section 11Section 2(15)Section 250

than Rs.25 Lakhs and hence the exemption u/s 11 shall not be granted to it as per the provisions of the proviso to section 2(15)? 2. Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in Ignoring the fact ... such activities will fall in the category of advancement of any other object of general public utility only hence applicability of proviso to section 2(15) should have been examined as the same result into denial of exemption u/s 11 of the I.T. Act? 3. Whether on the facts

Shrionkar Singh Memorial Trust, Delhi vs. CIT (Exemption), New Delhi

The appeal of the assessee is allowed for statistical purpose

ITA 1750/DEL/2024[NA]Status: DisposedITAT Delhi28 Aug 2024

Bench: 12/03/2024 Was Issued. The Appellant/Applicant Uploaded Certain Details & Documents On 12/03/2024. Reply Was Also Submitted By Appellant Vide Letter Dated 12/3/2024 & Requested To Submit The Documents & Clarifications.

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

documents erred in rejecting application for registration on the ground that appellant had not carried out any charitable activity as envisaged under section 2(15) of the Income Tax Act, 1961. 5. Learned Authorized Representative for department of revenue submitted that appellant/assessee failed to submit complete details regarding activities undertaken

Sea Cadet Corps Pune Unit, Pune vs. CIT, Exemption, Pune

ITA 949/PUN/2024[-]Status: DisposedITAT Pune26 Aug 2024

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.949/Pun/2024 Sea Cadet Corps Pune Unit S. No. 96/96, C-96-D, Plot No. 2, Flora Bunglow, A-6, Ground 15Th Flr, Mundhwa, Pune-411036 .......अपीलार्थी / Appellant Pan: Aazts6192E V/S The Commissioner Of Income Tax ....... प्रत्यर्थी / Respondent (Exemption), Pune

For Appellant: Smt Deepa Khare [‘Ld. AR’]For Respondent: Mr Ajaykumar Kesari [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)

operation as such [Constitution/Establishment] (iii) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (iv) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

Society for Welbeing Awearness and Rehabilitation Latur, Latur vs. CIT- Exemption, Pune

ITA 943/PUN/2024[-]Status: DisposedITAT Pune26 Aug 2024

Bench: Hon’Ble Shri Satbeer Singh Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No.943/Pun/2024 Society For Wellbeing Awareness & Rehabilitation Behind Mega Ajinkya City, Ambejogai Road, Latur-413512 .......अपीलार्थी / Appellant Pan: Aajts6718G V/S The Commissioner Of Income Tax ....... प्रत्यर्थी / Respondent (Exemption), Pune

For Appellant: None for the AssesseeFor Respondent: Mr Ajaykumar Kesari [‘Ld. DR’]
Section 12ASection 12A(1)(ac)Section 2(15)

operation as such [Constitution/Establishment] (iii) whether all the entries of object clause are in consonance with the ‘charitable purpose’ as defined by section 2(15) of the Act [Objects] (iv) whether there exist any implied or express provision in the constitutional & other administrative documents/policies etc., entitling any right or power

Sir Ratan Tata Trust, Mumbai Suburban vs. Additional /Joint/Deputy/Assistant Commissioner of Income Tax, NFAC, Mumbai

In the result, both the appeals of the assessee in both AY 2014-15 and AY

ITA 4156/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Aug 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri P. J. Pardiwala a/wFor Respondent: Shri Sanyogita Nagpal, CIT-DR
Section 1Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 2(15)

assessee has violated the provisions of section 13(1)(c) – AY 2018-19 (iv) The assessee has violated the provisions of section 2(15) – AY 2018-19 ITA No. 4154/Mum/2023 – AY 2014-15 3. The assessee is a Public Charitable Trust registered under Bombay Public Trust Act and under section ... section 11 for the reason that the assessee has violated the provisions of section 13(1)(c) of the Act. Violation of section 2(15) of the Act 31. The AO held that the assessee has violated the provisions of section 2(15) of the Act for the reason that

Sir Ratan Tata Trust, Mumbai Suburban vs. Deputy Commissioner of Income Tax (Exemption)-2(1), Mumbai

In the result, both the appeals of the assessee in both AY 2014-15 and AY

ITA 4154/MUM/2023[2014-15]Status: DisposedITAT Mumbai26 Aug 2024AY 2014-15

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri P. J. Pardiwala a/wFor Respondent: Shri Sanyogita Nagpal, CIT-DR
Section 1Section 10(34)Section 11Section 11(5)Section 12ASection 13(1)(c)Section 13(1)(d)Section 13(2)(h)Section 2(15)

assessee has violated the provisions of section 13(1)(c) – AY 2018-19 (iv) The assessee has violated the provisions of section 2(15) – AY 2018-19 ITA No. 4154/Mum/2023 – AY 2014-15 3. The assessee is a Public Charitable Trust registered under Bombay Public Trust Act and under section ... section 11 for the reason that the assessee has violated the provisions of section 13(1)(c) of the Act. Violation of section 2(15) of the Act 31. The AO held that the assessee has violated the provisions of section 2(15) of the Act for the reason that

Grameen First Development Foundation, Mumbai vs. Exemption Ward, Thane, Mumbai

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

ITA 1608/MUM/2024[2023-24]Status: DisposedITAT Mumbai23 Aug 2024AY 2023-24

Bench: Shri Prashant Maharishi, Am & Shrirahul Chaudhary, Jm A.Y.2023-24 Grameen First Development Exemption Ward, Thane Foundation, 108, Bldg. Quereshi Mansion No.A2, Phase I- Green Vs. Glade, Abachapada, Devkhop Villa Ge Palghar, Thane (Appellant) (Respondent) Pan Aajcg0602J Assessee By Shri Paras Manot Revenue By Dr Kishor Dhule, Cit(Dr)

Section 80GSection 80G(5)

A Y : 2023–24 Grameen First Development Foundation Versus Exemption Ward Thane Quereshi Mansion IN THE INCOME TAX APPELLATE TRIBUNAL

Tulsi Gramodyog Sewa Samiti, Lucknow vs. The Commissioner of Income Tax(Exemptions), Lucknow

In the result, the appeals of the assessee stands dismissed

ITA 224/LKW/2022[00]Status: FixedITAT Lucknow22 Aug 2024

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: NoneFor Respondent: Smt. Namita S. Pandey, CIT(DR)
Section 11Section 12ASection 80GSection 80G(5)

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER AND SHRI SUBHASH

Tulsi Gramodyog Sewa Samiti, Lucknow vs. The CIT (Exemptions), Lucknow

In the result, the appeals of the assessee stands dismissed

ITA 217/LKW/2022[00]Status: FixedITAT Lucknow22 Aug 2024

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

For Appellant: NoneFor Respondent: Smt. Namita S. Pandey, CIT(DR)
Section 11Section 12ASection 80GSection 80G(5)

IN THE INCOME TAX APPELLATE TRIBUNAL LUCKNOW BENCH “A”, LUCKNOW BEFORE SHRI ANADEE NATH MISSHRA, ACCOUNTANT MEMBER AND SHRI SUBHASH

Akshay Academy, Indore, M.P vs. The Income Tax Officer, NFAC, Delhi

In the result, the appeal of the assessee is allowed

ITA 199/IND/2024[2018-19]Status: DisposedITAT Indore20 Aug 2024AY 2018-19

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniakshay Academy Ito, Nfac 32 Kaimaidan Road, Delhi Khasgi Gagicha Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aadta8987B Assessee By Shri S.N. Agrawal, Ar Revenue By Shri Ram Kumar Yadav, Cit- Dr Date Of Hearing 06.08.2024 Date Of Pronouncement 20.08.2024

Section 10Section 11Section 12A

आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY

DCIT(Exemptions), Circle-2, Ahmedabad vs. Surat Urban Development Authority, Surat

In the result, the appeals filed by the Revenue in ITA Nos

ITA 227/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad14 Aug 2024AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

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

activities carried out of “advancement of other general public utility” in the nature of trade, commerce, business and therefore the provisions of Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption ... following Gujarat High Court judgment in assessee’s own case held that the assessee cannot be considered to cover by the proviso to section 2(15) of the Act which was been confirmed by the Hon’ble Supreme Court Judgment in Civil Appeal No. 21762 of 2017 in assessee

DCIT(Exemptions), Circle-2, Ahmedabad vs. Surat Urban Development Authority, Surat

In the result, the appeals filed by the Revenue in ITA Nos

ITA 226/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad14 Aug 2024AY 2016-17

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

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

activities carried out of “advancement of other general public utility” in the nature of trade, commerce, business and therefore the provisions of Section 2(15) read with proviso 1 & 2 were held to be applicable with the facts of the assessee’s case. Therefore the A.O. denied exemption ... following Gujarat High Court judgment in assessee’s own case held that the assessee cannot be considered to cover by the proviso to section 2(15) of the Act which was been confirmed by the Hon’ble Supreme Court Judgment in Civil Appeal No. 21762 of 2017 in assessee

Kerala Industrial Infrastruture Dev Corporation(Kinfra), Trivandrum vs. The Assistant Director of Income Tax(Exemption), Trivandrum

ITA 452/COCH/2014[2009-10]Status: DisposedITAT Cochin14 Aug 2024AY 2009-10

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Sukhsagar Syal, AdvocateFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 2(15)Section 260ASection 263

Kerala Industrial Infrastructure Development Act, 1993, hereinafter referred to as the 'KIID Act', is eligible for exemption under Section 11 read with Section 2(15) of the Income Tax Act or whether in terms of the first proviso to Section 2(15), they would become ineligible for such exemption. Thus ... income generated by way of premium and attendant income from that property and utilisation of that parcel. The question whether the proviso to Section 2(15) would apply is something that has to be decided on the basis of the activity or activities during a particular year which would fall

Assistant Director of Income-Tax(Exemption), Trivandrum vs. Kerala Industrial Infrastructure Dev.Corporation, Trivandrum

ITA 287/COCH/2014[2010-11]Status: DisposedITAT Cochin14 Aug 2024AY 2010-11

Bench: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Sri.Sukhsagar Syal, AdvocateFor Respondent: Sri.Sanjit Kumar Das, CIT-DR
Section 11Section 143(3)Section 2(15)Section 260ASection 263

Kerala Industrial Infrastructure Development Act, 1993, hereinafter referred to as the 'KIID Act', is eligible for exemption under Section 11 read with Section 2(15) of the Income Tax Act or whether in terms of the first proviso to Section 2(15), they would become ineligible for such exemption. Thus ... income generated by way of premium and attendant income from that property and utilisation of that parcel. The question whether the proviso to Section 2(15) would apply is something that has to be decided on the basis of the activity or activities during a particular year which would fall

The Crafts Council of India, Chennai vs. JCIT(Exemptions), Chennai

ITA 946/CHNY/2024[2016-17]Status: DisposedITAT Chennai14 Aug 2024AY 2016-17

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकरअपील सं./ Ita Nos.943, 944, 945 & 946/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-2012, 2013-14, 2015-16 & 2016-2017) The Crafts Council Of India, Vs. The Joint Commissioner Of Income Gf Temple Trees, Tax, Venkatnarayanana Road, (Exemptions) T. Nagar, Chennai 600 017. Chennai. [Pan: Aaatc 1433B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 01.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 14.08.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Ms. Gouthami Manivasagam, IRS, JCIT
Section 11Section 12ASection 143(3)Section 2(15)

income. During the assessment u/s 143(3) of the Income Tax Act, the Joint Commissioner of Income Tax (JCIT) invoked proviso to section 2(15) in respect of certain income which in herview were in the nature of trade and commerce and by denying the exemption available u/s 11, charged ... helping poor craftman who develop their skills and market their ware. The trust is only helping poor craftman and hence the proviso to section 2(15)will not apply. In any event the trust is acting only as the conduit pipe for the poor craft man to sell their crafts

The Crafts Council of India, Chennai vs. JCIT (Exemptions), Chennai

ITA 945/CHNY/2024[2015-16]Status: DisposedITAT Chennai14 Aug 2024AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकरअपील सं./ Ita Nos.943, 944, 945 & 946/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-2012, 2013-14, 2015-16 & 2016-2017) The Crafts Council Of India, Vs. The Joint Commissioner Of Income Gf Temple Trees, Tax, Venkatnarayanana Road, (Exemptions) T. Nagar, Chennai 600 017. Chennai. [Pan: Aaatc 1433B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 01.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 14.08.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Ms. Gouthami Manivasagam, IRS, JCIT
Section 11Section 12ASection 143(3)Section 2(15)

income. During the assessment u/s 143(3) of the Income Tax Act, the Joint Commissioner of Income Tax (JCIT) invoked proviso to section 2(15) in respect of certain income which in herview were in the nature of trade and commerce and by denying the exemption available u/s 11, charged ... helping poor craftman who develop their skills and market their ware. The trust is only helping poor craftman and hence the proviso to section 2(15)will not apply. In any event the trust is acting only as the conduit pipe for the poor craft man to sell their crafts

The Crafts Council of India, Chennai vs. JCIT(Exemptions), Chennai

ITA 944/CHNY/2024[2013-14]Status: DisposedITAT Chennai14 Aug 2024AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकरअपील सं./ Ita Nos.943, 944, 945 & 946/Chny/2024 (िनधा"रणवष" / Assessment Years: 2011-2012, 2013-14, 2015-16 & 2016-2017) The Crafts Council Of India, Vs. The Joint Commissioner Of Income Gf Temple Trees, Tax, Venkatnarayanana Road, (Exemptions) T. Nagar, Chennai 600 017. Chennai. [Pan: Aaatc 1433B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से /Respondent By : Ms. Gouthami Manivasagam, Irs, Jcit. सुनवाई क" तार"ख/Date Of Hearing : 01.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 14.08.2024 आदेश / O R D E R Manu Kumar Giri ()

For Appellant: Shri R. Vijayaraghavan, AdvocateFor Respondent: Ms. Gouthami Manivasagam, IRS, JCIT
Section 11Section 12ASection 143(3)Section 2(15)

income. During the assessment u/s 143(3) of the Income Tax Act, the Joint Commissioner of Income Tax (JCIT) invoked proviso to section 2(15) in respect of certain income which in herview were in the nature of trade and commerce and by denying the exemption available u/s 11, charged ... helping poor craftman who develop their skills and market their ware. The trust is only helping poor craftman and hence the proviso to section 2(15)will not apply. In any event the trust is acting only as the conduit pipe for the poor craft man to sell their crafts