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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 ACIT, Circle - 1(1), Visakhapatnam vs. Visakhapatnam Port Authority, Visakhapatnam

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 399/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

From AY 2003-04 to 2008-09, total income of the assessee was exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further ... From AY 2003-04 to 2008-09, total income of the assessee was 21 exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income

Visakhapatnam Port Authority, Visakhapatnam vs. The ACIT, Visakhapatnam

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 397/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

From AY 2003-04 to 2008-09, total income of the assessee was exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further ... From AY 2003-04 to 2008-09, total income of the assessee was 21 exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income

Visakhapatnam Port Authority, Visakhapatnam vs. The ACIT, Visakhapatnam

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 396/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

From AY 2003-04 to 2008-09, total income of the assessee was exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further ... From AY 2003-04 to 2008-09, total income of the assessee was 21 exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income

Visakhapatnam Port Authority, Visakhapatnam vs. The ACIT, Circle - 1(1), Visakhapatnam

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 26/VIZ/2014[2011-12]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

From AY 2003-04 to 2008-09, total income of the assessee was exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further ... From AY 2003-04 to 2008-09, total income of the assessee was 21 exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income

Visakhapatnam Port Authority, Visakhapatnam vs. The Addl. CIT., Visakhapatnam

In the result, CO raised by the assessee is disposed off as discussed herein above

ITA 25/VIZ/2014[2010-11]Status: DisposedITAT Visakhapatnam27 Sept 2023AY 2010-11

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./ I.T.A. No.25/Viz/2014 ("नधा"रणवष"/ Assessment Year :2010-11) Visakhapatnam Port Authority, Vs. Addl. Cit, (Formerly Known As M/S. Range-1, Visakhapatnam Port Trust) Visakhapatnam. Visakhapatnam. Pan: Aaalv0035C (अपीलाथ"/ Appellant) (""यथ"/ Respondent)

From AY 2003-04 to 2008-09, total income of the assessee was exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income’. Further ... From AY 2003-04 to 2008-09, total income of the assessee was 21 exempted U/s. 11 of the Act.Consequent to amendment to section 2(15) of the Act, the assessee filed its return of income for the AY 2009-10 onwards admitting its income under the head ‘business income

Indian Machine Tool Manufacturers Association, Mumbai vs. DCIT (Exem)-1(1), Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes, while the appeal by the Revenue is partly allowed for statistical purposes

ITA 82/MUM/2023[2014-15]Status: DisposedITAT Mumbai25 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri P.J. Pardiwala a/wFor Respondent: Shri Shambhu Yadav
Section 11Section 2(15)Section 250

commercial principles and the receipts from the such activities is more than 20% of the total receipt of the trust, the proviso to section 2(15) is applicable. 3. Whether on the facts and circumstances of the case and in law and in light of the law laid down ... ITAT erred in not appreciating that even if the activities of the assessee are held to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" even then it is not entitled to exemption u/s 11 because

DCIT (E)-1(1), Mumbai vs. Indian Machine Tools Mfrs Association, Mumbai

In the result, the appeal by the assessee is allowed for statistical purposes, while the appeal by the Revenue is partly allowed for statistical purposes

ITA 80/MUM/2023[2014-15]Status: DisposedITAT Mumbai25 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri P.J. Pardiwala a/wFor Respondent: Shri Shambhu Yadav
Section 11Section 2(15)Section 250

commercial principles and the receipts from the such activities is more than 20% of the total receipt of the trust, the proviso to section 2(15) is applicable. 3. Whether on the facts and circumstances of the case and in law and in light of the law laid down ... ITAT erred in not appreciating that even if the activities of the assessee are held to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" even then it is not entitled to exemption u/s 11 because

Sri Gurutegh Bahadur Education Society, Jabalpur vs. Commissioner of Income Tax, Exemption, Bhopal

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

ITA 95/JAB/2022[2022-23]Status: DisposedITAT Jabalpur22 Sept 2023AY 2022-23

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadalesri Gurutegh Bahadur Vs Cit (Exemption), Education Society, 1, Sri Bhopal. Gurutegh Bahadur Khalasa College, Mahanadda, Nagpur Road, Jabalpur, Madhya Pradesh-482002. (Appellant) (Respondent) Pan No.Aaeas6226R Assessee By Shri H.S.Modh, Adv. Revenue By Shri Shiv Kumar, Sr.Dr Date Of Hearing 18/09/2023 Date Of Pronouncement 22/09/2023

Section 12ASection 12A(1)(ac)

Financial Year relevant to the Assessment Year and all the provisions of law acted upon. This will be further subject to provisions of section 2(15) of the Income Tax Act, 1961. 7- No change in terms of Trust Deed/ Memorandum of Association shall be effected without due procedure

Mesers Improvement Trust, Fazilka vs. Deputy Commissioner of Income Tax Circle-1(Exemptions), Chandigarh

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

ITA 307/ASR/2018[2014-15]Status: DisposedITAT Amritsar20 Sept 2023AY 2014-15

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 11Section 13(8)Section 143(3)Section 2(15)Section 250Section 28

circumstances of the case and in law, the Ld. Commissioner of Income Tax (Appeals) has erred by holding that, since proviso to section 2(15) is applicable, section 13(8) gets invoked and as a result of section 13(8), the assessee appellant looses all the benefits of sections ... assessee was rejected for claimed of exemption u/s 11 and 12 by invoking section 13(8) as there is no application of section 2(15) in the activity of the assessee. In assessment the addition was made amount to Rs. 3 crore for payment towards public utility and amount

Laxminarayan Mandir Trust, Mumbai vs. Income Tax Officer (Exemption) 1(4), Mumbai

In the result, the appeal by the Revenue is dismissed, while the appeal by the assessee is allowed

ITA 3273/MUM/2022[2013-14]Status: DisposedITAT Mumbai18 Sept 2023AY 2013-14

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri B.N. RaoFor Respondent: Smt. Shailja Rai
Section 13Section 13(1)(c)Section 13(2)(a)Section 2(15)Section 250

lines and the same tantamount to a form of trade, commerce or business. Accordingly, such activities are covered by (para 253) interpretation of section 2(15) of the Act in the judgement of the Hon'ble Supreme Court dt. 19.10.2022 in AUDA Civil Appeal No. 21762 of 2017? 6. Whether

Income Tax Officer (Exemption)-1(4), Mumbai vs. Laxminarayan Mandir Trust, Mumbai

In the result, the appeal by the Revenue is dismissed, while the appeal by the assessee is allowed

ITA 3235/MUM/2022[2013-2014]Status: DisposedITAT Mumbai18 Sept 2023AY 2013-2014

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri B.N. RaoFor Respondent: Smt. Shailja Rai
Section 13Section 13(1)(c)Section 13(2)(a)Section 2(15)Section 250

lines and the same tantamount to a form of trade, commerce or business. Accordingly, such activities are covered by (para 253) interpretation of section 2(15) of the Act in the judgement of the Hon'ble Supreme Court dt. 19.10.2022 in AUDA Civil Appeal No. 21762 of 2017? 6. Whether

Sarfrosh Foundation, Moga vs. Commissioner of Income Tax ( Exemptions), Chandigarh

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

ITA 144/ASR/2023[2022-23]Status: DisposedITAT Amritsar13 Sept 2023AY 2022-23

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. S. K. Vatta, CAFor Respondent: Sh. Amit Jain, CIT DR
Section 12ASection 135Section 80G

without pointing out any deficiency in objects or activities of the Trust in violation of Sarfarosh Foundaton v. CIT provisions to proviso to section 2(15) of the Act, and discussion about the manner of activities being carried out by the company and whenever contributions made to the impugned Trust

Sarfrosh Foundation, Moga vs. Income Tax Officer ( Exemptions), Jalandhar

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

ITA 128/ASR/2023[2022-23]Status: DisposedITAT Amritsar13 Sept 2023AY 2022-23

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. S. K. Vatta, CAFor Respondent: Sh. Amit Jain, CIT DR
Section 12ASection 135Section 80G

without pointing out any deficiency in objects or activities of the Trust in violation of Sarfarosh Foundaton v. CIT provisions to proviso to section 2(15) of the Act, and discussion about the manner of activities being carried out by the company and whenever contributions made to the impugned Trust

Geeta Vidya Mandir Samiti, Gurgaon vs. CIT(E), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 1973/DEL/2020[2019-20]Status: DisposedITAT Delhi13 Sept 2023AY 2019-20

Bench: Shri N.K. Billaiya & Shri Kul Bharat

For Appellant: Shri K. R. Chhabra, AdvocateFor Respondent: Shri T. James Singson, CIT- DR
Section 11Section 12Section 12ASection 13(1)(c)Section 2(15)

donations received, including 6. corpus donation, received since inception/ during last three years. Please specify the category of charitable purposes 7. provided in section 2(15) of the Income-Tax Act, 1961 in which your case falls, i.e., whether your objective is relief of the poor/ education/ yoga/ medical relief ... giving clear undertaking that no fees charges 8. etc had been collected for any services referred from the beneficiaries inviolation of provisions of section 2(15) of Income Tax Act. Copies of Audited balance Sheets, Income & Expenditure 9. account along with complete annexure for the last 03 Years or since

M/S Santosh Foundation, Rampura Phul vs. Commissioner of Income Tax (Exemption), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 286/ASR/2017[2017-18]Status: DisposedITAT Amritsar12 Sept 2023AY 2017-18

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

For Appellant: Sh. Sudhir Sehgal & Sh. P.N. Arora, AdvFor Respondent: Sh. Hitendra Bhauraoji Ninawe, CIT DR
Section 12ASection 135(1)

IN THE INCOME TAX APPELLATE TRIBUNAL AMRITSAR BENCH, AMRITSAR BEFORE DR. M. L. MEENA, ACCOUNTANT MEMBER AND SH. ANIKESH BANERJEE

M/S Prayas Bahuddeshiya Samajik Sanstha, Nagpur vs. CIT Exemptions, Pune

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

ITA 7/NAG/2020[00]Status: DisposedITAT Nagpur12 Sept 2023

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.7/Nag/2020 िनधा"रण वष" / Assessment Year : - M/S.Prayas Bahudeshiya The Cit Exemption, Samajik Sanstha, Vs Pune. 246/247, Trikoni Maidan, Hanuman Nagar, Medical Road, Nagpur – 440009. Pan: Aafap 2641 G Appellant / Assessee Respondent / Revenue Assessee By Shri Kapil Hirani – Ca Revenue By Shri Kailash Kanojiya – Sr.Dr Date Of Hearing 31/08/2023 Date Of Pronouncement 12/09/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Assessee’S Application For Registration Under Section 12Aa(1)(B)(Ii) Of The Income Tax Act, 1961 Dated 29.11.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1. Whether On The Facts & Circumstances Of The Case The Cit(Exemptions), Pune Was Justified In Rejecting The Application Of M/S.Prayas Bahuddeshiya Samajik Sanstha [A]

Section 12ASection 2(15)

time of registration, ld.CIT(E) has to give a categorical finding whether the objects, activities of the assessee are charitable as per section 2(15) of the Act or not! In this case, the assessee is registered under Bombay Public Trust Act on 15.12.2014. Thus, assessee is in existence since

Indian Medical Association, Nagpur vs. CIT(Exemption), Pune

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

ITA 18/NAG/2020[00]Status: DisposedITAT Nagpur12 Sept 2023

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.18/Nag/2020 िनधा"रण वष" / Assessment Year : - Indian Medical Association, The Cit Exemption, Ima Building, Station Vs Pune. Road, Bhandara, Maharashtra – 441904. Pan: Aabti 7140 N Appellant / Assessee Respondent / Revenue Assessee By None Revenue By Shri Kailash Kanojiya – Sr.Dr Date Of Hearing 31/08/2023 Date Of Pronouncement 12/09/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Assessee’S Application For Registration Under Section 12Aa(1)(B)(Ii) Of The Income Tax Act, 1961 Dated 30.11.2019. The Assessee Has Raised The Following Grounds Of Appeal : “1. The Order Passed Is Without Basis & Is Bad In Law. Indian Medical Association [A]

Section 12A

Trust. The ld.CIT(E) needs to verify whether objects and activities are charitable as defined under 4 Indian Medical Association [A] section 2(15) of the Act. However, in this case ld.CIT(E) has not bothered to discuss anything about the objects of the trust and activities of the Trust

Vakrangee Foundation, Raipur vs. Deputy Commissioner of Income Tax (Exemption), Raipur

ITA 196/RPR/2023[2017-18]Status: DisposedITAT Raipur12 Sept 2023AY 2017-18

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.196/Rpr/2023 िनधा"रण वष" /Assessment Year: 2017-18 Vakrangee Foundation Vs Assessing Officer, 103, 1St Floor, Golden Park, Vip Exemption Circle, Estate, Vidhan Sabha Road, Raipur (Cg) Raipur (Cg) Pan: Aaaav8441K (अपीलाथ" /Appellant) .. (""यथ" / Respondent) िनधा"रती क" ओर से /Assessee By : Shri G.S.Agarwal, Ca राज"व क" ओर से /Revenue By : Shri Satya Parakash Sharma, Sr.Dr सुनवाई क" तार"ख / Date Of Hearing : 08/09/2023 घोषणा क" तार"ख/Date Of Pronouncement : 12/09/2023

For Appellant: Shri G.S.Agarwal, CAFor Respondent: Shri Satya Parakash Sharma, Sr.DR
Section 12ASection 2(15)Section 250Section 271Section 271BSection 44A

that it is a educational institution running a CBSE Affiliated school since inception and imparting education is an activity for charitable purpose under section 2(15) of the Act therefore provision of section 44AB which relates to persons carrying on Business will not be apply in assessee’s case. Therefore ... assessee is earning profit, registration u/s 12AA of the Act was granted to the assessee from AY 2018-19, therefore provision of section 2(15) of Act as claimed by the assessee is not applicable during the year under consideration. Ld AO with such observation, imposed penalty u/s 271B

Worldwelfare Health Federation, Jaipur vs. Commissioner of Income Tax(Exemption), Jaipur

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

ITA 350/JPR/2023[2022-23]Status: DisposedITAT Jaipur12 Sept 2023AY 2022-23

Bench: Rejecting The Application For Registration U/S 12Ab. No Show Cause Notice Before The Rejection Of The Application Was Issued To The Assessee. 3. That The Ld. Cit(Exemption) Has Not Given Adequate Time For Submitting Responses To Notices U/S 133(6). Notices Were Issued On 24/03/2023 (Friday) To Three Parties & Without Waiting For Their Responses, The Order Of Rejection Was Issued On 28/03/2023 (Tuesday) In A Hurried Manner. 4. Appellant Craves The Right To Add, Alter, Modify Or Amend In Any Manner The Grounds Of Appeal On Or Before The Hearing.”

For Appellant: Sh. Praveen Saraswat (CA)For Respondent: Sh. Ajay Malik (CIT)
Section 12ASection 133(6)

Therefore, such receipts are receipts from trade and commerce and cannot be termed as charitable within the ambit of section 2(15) of the Act.” (Page No. 6 of the CIT order) Submission of the appellant: 1.1.1 Section 12AB (1) (b) (ii) lays down that: __________________________________________________________________ “after satisfying himself about ... Therefore, such receipts are receipts from trade and commerce and cannot be termed as charitable within the ambit of section 2(15) of the Act.” (Page No. 6 of the CIT order) 1.5.1 Whether `Medical research’ is `Medical Relief’ for being Charitable Purpose’ within the definition of Section 2(15

ITO (Exemption), Udaipur vs. Tatpadam Upavan, Rajsamand

In the result, appeal of the revenue is dismissed

ITA 161/JODH/2020[2017-18]Status: DisposedITAT Jodhpur06 Sept 2023AY 2017-18

Bench: The Hon’Ble Tribunal In The Interest Of Justice.”

Section 11Section 12Section 12ASection 143(3)Section 2(15)Section 25Section 80

Appeals) has erred in allowing exemption u/s 11 of the IT. Act, 1961 to the assessee despite the fact that the proviso to section 2(15) is invoked in the case of the assessee as the activities of the assessee are being run on commercial basis, there being no element ... Thus, the percentage receipt from organizing of this program against total receipts works out to be more than 28%. As per proviso to section 2(15), the advancement of any other object of general public utility shall not be a charitable purpose if it involves the carrying