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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)

Kakatiya Urban Development Authority, Warangal vs. Asst. Commissioner of Income Tax, (Exemptions), Hyderabad

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 1722/HYD/2019[2009-10]Status: DisposedITAT Hyderabad26 Dec 2022AY 2009-10

Bench: Before Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Ms. SandhyaFor Respondent: Shri Jeevanlal Lavidiya –
Section 25l

overall income as receipts as part of trade, commerce or business, the quantitative limit of 20% imposed by second proviso to Section 2(15) would ITA Nos.1877 to 1881/Hyd/2019 be attracted thereby negating the essential general public utility object and thus driving up the costs to be borne ... quantitative limit resulting in taxation and the consequent higher consideration charged from the user or consumer. (a) Interpretation of Section 10(46) and Section 2(15) 178. Section (20A) was inserted by Finance Act, 1970 with effect from 01 04 1962 It had excluded certain classes of income, of corporations

M/S Kotalipara Development Society, Barasat vs. I.T.O.(Exemption), Ward-1(4), Kolkata

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

ITA 164/KOL/2020[2013-14]Status: DisposedITAT Kolkata21 Dec 2022AY 2013-14

Bench: Dr. Manish Boradi.T.A No.164/Kol/2020 Assessment Year: 2013-14 M/S Kotalipara Development Society....................................................…… …. Appellant Pioneer Para, Noapara, P.O. Barasat, North 24 Parganas, W.B. 700124. [Pan:Aaaak3272B] Vs. Ito(Exemption), Ward-1(4), Kolkata........................................................….. Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Vijay Kumar, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 13, 2022 Date Of Pronouncing The Order : December 21, 2022 आदेश / Order

Section 143(3)Section 2(15)Section 250

petition. 2. FOR THAT both court below never considered the documents produced at the time of hearing before disallowed the amended provision of section 2(15) of the Income Tax Act, 1961. I.T.A No.164/Kol/2020 Assessment year: 2013-14 M/s Kotalipara Development Society 3. FOR THAT both the court below

Lady Tata Memorial Trust, Mumbai-400001 vs. Commissioner of Income Tax (Exemptions), Mumbai-400026

ITA 1158/MUM/2022[2022-23]Status: DisposedITAT Mumbai30 Nov 2022AY 2022-23

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2022-23

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Smt Shailja Rai, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(iv)

10BE, as per the provisions of rule 18AB. e. No cess or fee or any other consideration shall be received in violation of section 2(15) of the Income Tax Act, 1961. f. The trust/society/non profit company shall file the return of income of its trust/society/non profit company

Lady Meherbai D Tata Education Trust, Mumbai-400001 vs. Commissioner of Income Tax (Exemptions), Mumbai

ITA 1157/MUM/2022[2022-23]Status: DisposedITAT Mumbai30 Nov 2022AY 2022-23

Bench: Shri Kuldip Singh & Shri S. Rifaur Rahmanassessment Year: 2022-23

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Smt Shailja Rai, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)Section 80G(5)(iv)

10BE, as per the provisions of rule 18AB. e. No cess or fee or any other consideration shall be received in violation of section 2(15) of the Income Tax Act, 1961. f. The trust/society/non profit company shall file the return of income of its trust/society/non profit company

Institute of Chemical Technology, Mumbai vs. NFAC, Delhi-Ds, Commissioner of Income Tax(A), Income Tax Dept-1, Delhi

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

ITA 1086/MUM/2022[2017-18]Status: DisposedITAT Mumbai28 Nov 2022AY 2017-18
Section 10Section 11Section 143(3)

accordingly, the revenue earned from consultancy activity cannot be regarded as charitable in view of the provisions of section 2(15) r.w.s 11 and 12 of the Act. Accordingly, the ld. AO disallowed assessee's claim of exemption only with regard to its share in consultancy fee received, though ... activity of rendering any service in relation to any trade, commerce or business for a fee, hence, is covered under the proviso to section 2(15) r/w section 11(4) and 11(4A) of the Act. To overcome the effect of the aforesaid decision the contention of the assessee

Institute of Chemical Technology, Mumbai vs. NFAC-Delhi-Ds Commissioner of Income Tax (A) Income Tax Dept 1, Delhi

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

ITA 1082/MUM/2022[2013-14]Status: DisposedITAT Mumbai28 Nov 2022AY 2013-14
Section 10Section 11Section 143(3)

accordingly, the revenue earned from consultancy activity cannot be regarded as charitable in view of the provisions of section 2(15) r.w.s 11 and 12 of the Act. Accordingly, the ld. AO disallowed assessee's claim of exemption only with regard to its share in consultancy fee received, though ... activity of rendering any service in relation to any trade, commerce or business for a fee, hence, is covered under the proviso to section 2(15) r/w section 11(4) and 11(4A) of the Act. To overcome the effect of the aforesaid decision the contention of the assessee

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2583/CHNY/2019[2012-13]Status: DisposedITAT Chennai18 Nov 2022AY 2012-13

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

learned CIT(Appeals) - 10 ought not to have held that the tuition centres run by the Trust are hit be the provisions of section 2(15) of the Income Tax Act 1961 and ought not to have rejected the appellant Trust's plea that they would come under the term ... general public utility as defined under last limb of charitable trust u/s. 2(15) of the Act and thus, by considering proviso to section 2(15) of the Act, rejected exemption claimed u/s. 11 & 12 of the Act and assessed total income as AOP and determined income

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2582/CHNY/2019[2011-12]Status: DisposedITAT Chennai18 Nov 2022AY 2011-12

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

learned CIT(Appeals) - 10 ought not to have held that the tuition centres run by the Trust are hit be the provisions of section 2(15) of the Income Tax Act 1961 and ought not to have rejected the appellant Trust's plea that they would come under the term ... general public utility as defined under last limb of charitable trust u/s. 2(15) of the Act and thus, by considering proviso to section 2(15) of the Act, rejected exemption claimed u/s. 11 & 12 of the Act and assessed total income as AOP and determined income

Equitas Development Initiatives Trust, Chennai vs. ITO Exemption Ward-3, Chennai

In the result, the appeals filed for all three assessment years are allowed for statistical purposes

ITA 2082/CHNY/2019[2013-14]Status: DisposedITAT Chennai18 Nov 2022AY 2013-14

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2582, 2583 & 2082/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13 & 2013-14

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Shri. AR V Sreenivasan, Addl. CIT
Section 11Section 12ASection 2(15)

learned CIT(Appeals) - 10 ought not to have held that the tuition centres run by the Trust are hit be the provisions of section 2(15) of the Income Tax Act 1961 and ought not to have rejected the appellant Trust's plea that they would come under the term ... general public utility as defined under last limb of charitable trust u/s. 2(15) of the Act and thus, by considering proviso to section 2(15) of the Act, rejected exemption claimed u/s. 11 & 12 of the Act and assessed total income as AOP and determined income

DCIT (E) 2(1), Mumbai vs. Neia Trust, Mumbai

In the result, all the appeals of the revenue stand dismissed

ITA 2168/MUM/2022[2013-14]Status: DisposedITAT Mumbai15 Nov 2022AY 2013-14

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: Mahesh AkhadeFor Respondent: Arati Vissanji
Section 10Section 11Section 12ASection 13(8)Section 143(2)Section 2(15)Section 250

total receipts of the assessee from such activities are more than 20% of the total receipt of the trust, hence the proviso to section 2(15) of the 1.T. Act is applicable and the assessee is not entitled to exemption u/s 11 of the Act in view ... receipts from the same are more than 20% of the total receipt of the trust, the proviso to section 2(15) is applicable?" 3. Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in allowing the benefit of exemption

DCIT (E) 2(1), Mumbai vs. Neia Trust, Mumbai

In the result, all the appeals of the revenue stand dismissed

ITA 2167/MUM/2022[2016-17]Status: DisposedITAT Mumbai15 Nov 2022AY 2016-17

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: Mahesh AkhadeFor Respondent: Arati Vissanji
Section 10Section 11Section 12ASection 13(8)Section 143(2)Section 2(15)Section 250

total receipts of the assessee from such activities are more than 20% of the total receipt of the trust, hence the proviso to section 2(15) of the 1.T. Act is applicable and the assessee is not entitled to exemption u/s 11 of the Act in view ... receipts from the same are more than 20% of the total receipt of the trust, the proviso to section 2(15) is applicable?" 3. Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in allowing the benefit of exemption

DCIT (E)- 2(1), Mumbai vs. Neia Trust, Mumbai

In the result, all the appeals of the revenue stand dismissed

ITA 2166/MUM/2022[2017-18]Status: DisposedITAT Mumbai15 Nov 2022AY 2017-18

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: Mahesh AkhadeFor Respondent: Arati Vissanji
Section 10Section 11Section 12ASection 13(8)Section 143(2)Section 2(15)Section 250

total receipts of the assessee from such activities are more than 20% of the total receipt of the trust, hence the proviso to section 2(15) of the 1.T. Act is applicable and the assessee is not entitled to exemption u/s 11 of the Act in view ... receipts from the same are more than 20% of the total receipt of the trust, the proviso to section 2(15) is applicable?" 3. Whether, on the facts and in the circumstances of the case and in law, the Ld. CIT(A) was justified in allowing the benefit of exemption

DCIT, Chennai vs. The Willingdon Charitable Trust, Chennai

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

ITA 587/CHNY/2015[2011-12]Status: DisposedITAT Chennai14 Oct 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.587/Chny/2015 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. The Willingdon Charitable Trust, Income Tax (Exemptions), Chennai Rani Seethai Hall, No. 603, Anna Salai, Circle, Aayakar Bhavan, Annexe Chennai 600 006. Building, Iii Floor, 121, M.G. Road, Nungambakkam, Chennai 600 034. [Pan:Aaatt0683N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 03.08.2022 घोषणा की तारीख /Date Of Pronouncement : 14.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai, Dated 12.12.2014 Relevant To The Assessment Year 2011-12. The Revenue Has Raised The Following Grounds: Ground No.1 1. The Order Of The Learned Cit (A) Is Contrary To The Law & Facts Of The Case. Ground No:2: 2.1 The Id Cit(A) Erred In Holding That The Assessee Is Eligible For Exemption U/S 11 Of The Act & Not Hit By The Amended Provisions Of Sec.2(15) Of The Act, Under The Object Of "General Public Utility".

For Appellant: Shri D. Hema Bhupal, JCITFor Respondent: Shri S. Sridhar, Advocate
Section 11Section 2(15)

payment of service tax by the assessee, under the category of "mandap-keeper services", brings it within the ambit of the provisos to Section 2(15) of the I.T. Act, 1961. Ground No.5: 5.1 The Id. CIT (A) erred in holding that the "predominant activities" of the assessee are "charitable ... examined by the Assessing Officer, but such observations would not have any relevance after insertion of two provisos to section 2(15) of the I.T. Act, 3 I.T.A. No. 587/Chny/15 1961, w.e.f. 01.04.2009 as the decision in the aforesaid case related to A.Y 1995-96 to A.Y 2005-06. Ground

Maharashtra Housing & Area Development Authority, Mumbai vs. Asst CIT (E) 2(1), Mumbai

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

ITA 5597/MUM/2017[2013-14]Status: DisposedITAT Mumbai12 Oct 2022AY 2013-14

Bench: Shri Aby T. Varkey, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.5597/Mum/2017 (निर्धारण वर्ा / Assessment Year: 2013-14) Maharashtra Housing & Acit (Exemption)-2(1) बिधम/ Area Development Piramal Chambers, Vs. Office Of Finance Lalbaug, Mumbai- Controller, Mhada, 4Th 400012. Floor, Griha Nirman Bhavan, Kala Nagar, Bandra (E), Mumbai- 400051. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaajm0344H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Nishant Thakkar/Ms. Jasmine Amalsadvala Revenue By: Shri S. H. Usmani (Dr) सुनवाई की तारीख / Date Of Hearing: 19/09/2022 घोषणा की तारीख /Date Of Pronouncement: 12/10/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-01, Mumbai Dated 28.06.2017 For Assessment Year 2013-14. 2. The Grounds Of Appeal Preferred By Assessee Are As Under: - “1.0 Denial Of Exemption Under S. 11 The Learned Cit(A) Erred On Facts & Circumstances Of The Case & In Law In Upholding The Assessment Order Appealed Against Denying Exemption Under S.11 Of The Act. Relief Claimed: The Appellant Be Granted Exemption Under S.11 Of The Act. 2.0 Engaged In Business:

For Appellant: Shri Nishant Thakkar/Ms. JasmineFor Respondent: Shri S. H. Usmani (DR)
Section 11(1)(a)Section 11(2)Section 234B

exemption claimed by the assessee u/s 11 of the Income Tax Act, 1961 (hereinafter “the Act”) on the ground that proviso to Section 2(15) of the Act is applicable to the assessee. 4. At the outset, the Ld. Counsel for the assessee submitted that the aforesaid issue is covered ... subject to exemption in the manner laid down in Section 11 to 13 of the Act. But in AY. 2009-10, proviso to Section 2(15) of the Act was inserted w.e.f 01.04.2009, whereby a restriction has been imposed on the trusts/assessee carrying out general public utility. Citing this proviso

Sir Dorabji Tata Trust, Mumbai vs. CIT (Exemptions), Mumbai

ITA 2206/MUM/2021[AY 2022-2023 TO AY 2026-27]Status: DisposedITAT Mumbai29 Sept 2022

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Years: 2022-23 To 2026-27 Sir Ratan Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats1013P Pedder Road, Mumbai – 400 026 (Appellant) (Respondent) Assessment Years: 2022-23 To 2026-27 Sir Dorabji Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats0494G Pedder Road, Mumbai – 400 026 (Appellant) (Respondent)

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Shri Kailash Kanojia, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)(iv)

10BE, as per the provisions of rule 18AB. e. No cess or fee or any other consideration shall be received in violation of section 2(15) of the Income Tax Act, 1961. f, The trust/society/non profit company shall file the return of income of its trust/society/non profit company

Sit Ratan Tata Trust, Mumbai vs. Commissioner of Income Tax (Exemptions), Mumbai

ITA 2204/MUM/2021[AY 2022-23 TO AY 2026-27]Status: DisposedITAT Mumbai29 Sept 2022

Bench: Shri Kuldip Singh & Shri Amarjit Singhassessment Years: 2022-23 To 2026-27 Sir Ratan Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats1013P Pedder Road, Mumbai – 400 026 (Appellant) (Respondent) Assessment Years: 2022-23 To 2026-27 Sir Dorabji Tata Trust, Commissioner Of Income Bombay House, Tax (Exemptions), 6Th Floor, Cumballa Hill, 24 Homi Modi Street, Vs. Fort, Mumbai – 400 001 Mtnl Building, Pan: Aaats0494G Pedder Road, Mumbai – 400 026 (Appellant) (Respondent)

For Appellant: Shri Sukhsagar Syal, A.RFor Respondent: Shri Kailash Kanojia, D.R
Section 12ASection 2(15)Section 80GSection 80G(5)(iv)

10BE, as per the provisions of rule 18AB. e. No cess or fee or any other consideration shall be received in violation of section 2(15) of the Income Tax Act, 1961. f, The trust/society/non profit company shall file the return of income of its trust/society/non profit company

Goregaon Sports Club, Mumbai vs. ACIT (E) 1(1), Mumbai

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

ITA 6686/MUM/2019[2014-15]Status: DisposedITAT Mumbai29 Sept 2022AY 2014-15

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Ms. Priyanka JainFor Respondent: Shri Hoshang B. Irani
Section 11Section 12ASection 143(3)Section 2Section 2(15)Section 250

raised following grounds: “1. The Ld CIT (A) erred in confirming order of AO, denying the exemption of Income U/S 11 read with Section 2(15) ignoring the orders of Hon'ble Tribunal for last more than 10 years including that of AY. 2012-13 order dt. 16.05.2018, which were ... arising in grounds no. 1 and 2, raised in assessee’s appeal, is pertaining to denial of exemption under section 11 read with section 2 (15) of the Act. 5. The brief facts of the case pertaining to this issue, as emanating from the record, are: The assessee

Goregaon Sports Club, Mumbai vs. ACIT (E) 1(1), Mumbai

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

ITA 6685/MUM/2019[2013-14]Status: DisposedITAT Mumbai29 Sept 2022AY 2013-14

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

For Appellant: Ms. Priyanka JainFor Respondent: Shri Hoshang B. Irani
Section 11Section 12ASection 143(3)Section 2Section 2(15)Section 250

raised following grounds: “1. The Ld CIT (A) erred in confirming order of AO, denying the exemption of Income U/S 11 read with Section 2(15) ignoring the orders of Hon'ble Tribunal for last more than 10 years including that of AY. 2012-13 order dt. 16.05.2018, which were ... arising in grounds no. 1 and 2, raised in assessee’s appeal, is pertaining to denial of exemption under section 11 read with section 2 (15) of the Act. 5. The brief facts of the case pertaining to this issue, as emanating from the record, are: The assessee

Slum Rehabilitation Authority, Mumbai vs. The ACIT(Exemption) Circle-2, Mumbai

In the result, all the appeals by the assessee are allowed for statistical purpose

ITA 1998/MUM/2020[2016-17]Status: DisposedITAT Mumbai28 Sept 2022AY 2016-17

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

Section 10Section 10(20)Section 11Section 12ASection 250

show cause as to why exemption under section 11 of the Act, as claimed, be not denied in view of amendment to section 2(15) of the Act. In reply, assessee submitted that proviso to section 2(15) was introduced with effect from assessment year 2009–10 and the issue ... assessment proceedings. However, the issue was dropped pursuant to reply of the assessee and the assessment was made without invoking proviso to section 2(15) of the Act. The assessee further submitted that there is no change in the facts of the case since earlier assessment years. The assessee also

Slum Rehabilitation Authority, Mumbai vs. DCIT (E)-2(1), Mumbai

In the result, all the appeals by the assessee are allowed for statistical purpose

ITA 700/MUM/2019[2015-16]Status: DisposedITAT Mumbai28 Sept 2022AY 2015-16

Bench: Shri Om Prakash Kant & Shri Sandeep Singh Karhail

Section 10Section 10(20)Section 11Section 12ASection 250

show cause as to why exemption under section 11 of the Act, as claimed, be not denied in view of amendment to section 2(15) of the Act. In reply, assessee submitted that proviso to section 2(15) was introduced with effect from assessment year 2009–10 and the issue ... assessment proceedings. However, the issue was dropped pursuant to reply of the assessee and the assessment was made without invoking proviso to section 2(15) of the Act. The assessee further submitted that there is no change in the facts of the case since earlier assessment years. The assessee also