← All Phrases

“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)

Sri Ajeya Sankara Trust, Tirupati vs. CIT (Exemption), Hyderabad

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

ITA 1366/HYD/2025[2025-26]Status: DisposedITAT Hyderabad12 Nov 2025AY 2025-26

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1366/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2025-26) Sri Ajeya Sankara Trust Vs. Cit (Exemption) Tirupati Hyderabad Pan:Aaxts2264F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate H. Srinivasulu राज" व "ारा/Revenue By:: Dr.Narendra Kumar Naik, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 16/10/2025 घोषणा की तारीख/Pronouncement: 12/11/2025 आदेश/Order Per Vijay Pal Rao, Vice-: This Appeal By The Assessee Is Directed Against The Order Dated, 17/05/2025 Of Cit (Exemption) Whereby The Application Of The Assessee In Form 10Ab Seeking Regular Approval U/S 80G Of The Act Was Rejected On The Ground Of Barred By Limitation.

For Appellant: Advocate H. SrinivasuluFor Respondent: : Dr.Narendra Kumar Naik, CIT(DR)
Section 12ASection 2(15)Section 80G

ITA No 1366 of 2025 Sri Ajeya Sankara Trust आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX

Ram Saran Das Kishori Lal Charitable Trust, Delhi vs. CIT(Exemption), Delhi

The appeal of the assessee is allowed

ITA 5290/DEL/2024[-]Status: DisposedITAT Delhi12 Nov 2025

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma[Assessment Year: -------] Ram Saran Das Kishori Lal Commissioner Of Income Tax Charitable Trust, (Exemption), Room No.24.05, E-2 Block, 24Th Floor, Civic Centre, A-27, Friends Colony East, Vs New Delhi-110001 New Delhi-110002 Pan-Aaatr0783P Appellant Respondent Appellant By Shri Ajay Vohra, Sr. Adv. & Shri Aditya Vohra, Adv. Shri Arpit Goyal, Adv. Respondent By Shri Amit Jain, Cit-Dr Date Of Hearing 09.09.2025 Date Of Pronouncement 12.11.2025

Section 127(2)Section 12ASection 2(15)

Appellant under section I2AA(3)/12AB(4), stating that it was found that the Trust has violated the provisions of section 2(15) r.w.s 12AA as the Trust was engaged in profit making activities and activities of the Trust are not genuine and not as per the objects

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5429/MUM/2025[2017-18]Status: DisposedITAT Mumbai11 Nov 2025AY 2017-18

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5428/MUM/2025[2016-17]Status: DisposedITAT Mumbai11 Nov 2025AY 2016-17

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5427/MUM/2025[2015-16]Status: DisposedITAT Mumbai11 Nov 2025AY 2015-16

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5426/MUM/2025[2014-15]Status: DisposedITAT Mumbai11 Nov 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5425/MUM/2025[2013-14]Status: DisposedITAT Mumbai11 Nov 2025AY 2013-14

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5424/MUM/2025[2012-13]Status: DisposedITAT Mumbai11 Nov 2025AY 2012-13

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5423/MUM/2025[2011-12]Status: DisposedITAT Mumbai11 Nov 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Gia India, Mumbai vs. A/DCIT (E) - 1(1), Mumbai

ITA 5422/MUM/2025[2010-11]Status: DisposedITAT Mumbai11 Nov 2025AY 2010-11

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 10Section 11Section 11(4)Section 2Section 2(15)Section 25Section 250

that the activities of the assessee are for advancement of general public utility in nature and is hit by the First Proviso to Section 2(15) of the Act,as the assessee has undertaken activities in the nature of business and the services in relation to business industry of gems ... cause notice requiring the assessee to explain as to why its case is not hit by Section 11(4) and First Proviso to Section 2(15) of the Act. The assessee submitted before the AO that the activities undertaken are for "imparting education" amongst the students in the field

Iqbal Mohamed Trust, Lovedale vs. CIT, Exemption, Chennai

In the result, the appeal is allowed for statistical purposes

ITA 539/CHNY/2025[-]Status: DisposedITAT Chennai04 Nov 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr.T. Banusekar, Advocate &For Respondent: Ms. E. Pavuna Sundari, CIT
Section 12ASection 12A(1)(ac)Section 2(15)

activity of teaching photography does not vity of teaching photography does not fall within the ambit of education as per Section 2(15) of the Act and that fall within the ambit of education as per Section 2(15) of the Act and that fall within the ambit of education ... Section 2(15) of the Act and that the assessee trust also does not have any recognition or affiliation with the assessee trust also does not have any recognition or affiliation with the assessee trust also does not have any recognition or affiliation with any university or government agency

Shree Brahmajyoti Sanskar Dham Trust, Surat vs. The Commissioner of Income Tax, (Exemption) Ahmedabad, Ahmedabad

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

ITA 74/SRT/2025[2025-26]Status: DisposedITAT Surat31 Oct 2025AY 2025-26

Bench: Ms. Suchitra Raghunath Kamble & Shri Bijayananda Prusethआयकर अपील सं./Ita No.74/Srt/2025 Assessment Year: (2025-26) (Hybrid Hearing) Shree Brahmajyoti Sanskar Dham Trust, Vs. Cit (Exemption), 9, Gopal Krushna Society, Behind Arihant Ahmedabad Park, Ambika Niketan, Athwalines, Surat – 395007, Gujarat "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aawts9225R (Appellant) (Respondent) Appellant By Shri Hiren Vepari, Ca Respondent By Shri Ravi Kant Gupta, Cit-Dr Date Of Hearing 19/08/2025 Date Of Pronouncement 31/10/2025

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

issued notices on 13.08.2024, 01.10.2024 and 01.11.2024. He has discussed legal background of Rule 11AA(1), 11AA(2) along with sections 2(15) and 80G(5) of the Act. He noted that the date of application for registration for approval in Form No.10AB was 11.05.2024 and the date of provisional ... taxmann.com 446 (Agra – Trib.) and (ii) OM Tapovan Charitable Trust vs. CIT(E), ITA No.175/Ahd/2023 (Ahd – Trib.). He discussed the provisions of section 2(15), 80G(5) and 80G(5B) and 80G(5)(ii) of the Act and referred the decision of Hon’ble Supreme Court in case of Director

Harmony Educational Foundation, Pune vs. CIT(E), Pune

In the result, appeal of the Assessee is dismissed

ITA 1993/PUN/2024[2025-26]Status: DisposedITAT Pune31 Oct 2025AY 2025-26

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1993/Pun/2024 निर्धारण वषा / Assessment Year: 2025-26 Harmony Educational V The Commissioner Of Foundation, S Income Tax(Exemption), 1430, Satav Vasti, Wagholi Pune. Lohegaon Road, Wagholi, Pune – 411047. Maharashtra. Pan: Aafch1576E Appellant/ Assessee Respondent / Revenue Assessee By Ca Abhay A Avchat & Mrs.Ruchi Agarwal(Director) – Ar Revenue By Shri Amol Khairnar – Cit(Dr) Date Of Hearing 28/10/2025 Date Of Pronouncement 31/10/2025 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) Dated 24.07.2024 Rejecting Registration Under Section 12A(1)(Ac) Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal:

Section 12ASection 12A(1)(ac)

Production House for Educational games, Toys and Sale the same is not a charitable object as defined in section 2(15) of the Income Tax Act. 20. In these facts and circumstances of the case, we are of the opinion that ld.CIT(E) was right in rejecting assessee‟s application ... held as under : „There should be activity of normal schooling or actual imparting of education by the institution.‟ 22. For the purpose of Section 2(15) of the Income Tax Act, Education means Structured Education. In the case of the Assessee, Assessee is running a school without having approval

R. Mangaldas Charitable Trust, Mumbai vs. CIT(Exemption), Mumbai

In the result, the appeal of assessee is allowed

ITA 17/MUM/2025[N.A ]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharyr. Mangaldas Charitable Trust, Cit (Exemptions), A-82, Vishnu Baug, Room No. 601, 137, S.V. Road, Vs. 6Th Floor, Andheri (W), Cumballa Hills, Mumbai-400058. Mtnl Te Building, Pedder Road, Pan : Aaatr0606H Dr.Gopalrao Deshmukh Marg, Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

granting registration u/s 12A of the Act. The scheme of the Act is that all entities carrying out charitable activities, as defined in section 2(15) of the Act, qualify to be registered as charitable entities subject to satisfaction of the concerned officer vis a vis their objects and activities

Mitra Parivar, Mumbai vs. CIT(Exemption), Mumbai

In the result, the appeal of assessee is allowed

ITA 16/MUM/2025[N.A]Status: DisposedITAT Mumbai31 Oct 2025

Bench: Shri Vikram Singh Yadav & Shri Rahul Chaudharymitra Parivar, Cit (Exemptions), 301, Maganlal Kala, Room No. 601, Gulmohar Road No.1, Vs. 6Th Floor, Jvpd Extn. Cumballa Hills, Andheri (West), Mtnl Te Building, Pedder Road, Mumbai-400049. Dr.Gopalrao Deshmukh Marg, Pan : Aaatm5059M Cumballa Hill, Mumbai-400026. (Appellant) (Respondent) For Assessee : Mr. Niraj Seth For Revenue : Shri Umashankar Prasad, Cit-Dr Date Of Hearing : 01-10-2025 Date Of Pronouncement : 31-10-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Exemptions)-Mumbai [„Ld.Cit(E)‟], Dated 19-11-2024, Rejecting The Assessee‟S Application Moved U/S. 80G(5)(Iii) Of The Income Tax Act, 1961 („The Act‟).

For Appellant: Mr. Niraj SethFor Respondent: Shri Umashankar Prasad, CIT-DR
Section 11Section 80GSection 80G(5)Section 80G(5)(iii)

granting registration u/s 12A of the Act. The scheme of the Act is that all entities carrying out charitable activities, as defined in section 2(15) of the Act, qualify to be registered as charitable entities subject to satisfaction of the concerned officer vis a vis their objects and activities

Agrasen Medical Relief & Research Society, Jaipur vs. ITO(E), Ward-1, Jaipur

In the result, the appeal of the assessee is allowed

ITA 1026/JPR/2025[2016-17]Status: DisposedITAT Jaipur30 Oct 2025AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं./ITA No. 1026/JPR/2025 निर्धरणवर्ष / AssessmentYear : 2016-17 Agrasen Medical Relief & Research Society Central Spine, Sector -7, Vidhyadhr Nagar Jaipur - 302 039 (Raj) बनाम Vs. अपीलार्थी / Appellant स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AAATA 7540F The ITO (E) Ward - 1 Jaipur प्रत्यर्थी / Respondent निर्धारिती की ओरसे / Assesseeby :Shri P.C.Parwal, CA राजस्व की ओरसे /Revenue by: Shri Gautam Singh Choudh

For Appellant: Shri P.C.Parwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 11Section 12ASection 12A(1)(ac)Section 143(3)Section 194JSection 2(15)Section 80G

word corpus fund at a later stage and therefore he considered amount of Rs.30,19,100/- as voluntary donation. Further by referring to section 2(15) of the Act it is observed that assessee declared receipt of Rs.16,45,911/- out of total receipt of Rs.64,80,355/- as received ... WARD-1, JAIPUR receipt from Sigma Electric Manufacturing Pvt. Ltd. will be below 20% of the total income, hence proviso to section 2(15) would not apply. Further it is stated that though the assessee could not furnish copy of registration certificate u/s 12A but registration certificate

The Bengal Chamber of Commerce and Industry, Kolkata vs. Deputy Director of Income Tax (Exemp) - 1, Kolkata

In the result, the appeal of the assessee is allowed

ITA 758/KOL/2025[2010-2011]Status: DisposedITAT Kolkata30 Oct 2025AY 2010-2011

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 758/Kol/2025 Assessment Year: 2010-2011 The Bengal Chamber Of Commerce & Industry,…………………………………………...……Appellant 2Nd Floor, 6, Royal Exchange Building, Kolkata-700001, West Bengal [Pan:Aabct1467A] -Vs.- Deputy Director Of Income Tax,……………..Respondent (Exemption)-1, Kolkata, 10B, Middleton Row, Kolkata-700071

Section 12ASection 142(1)Section 143(1)Section 143(2)

Chamber of Commerce (supra), we hold that no material change took place in the legal position even after the amendment was brought in section 2(15) by the Finance Act, 2008. W, therefore, do not find merit in the findings of the ld. CIT(A) that the assessee would

Neuro Update Chennai, Chennai vs. ITO, Exemption Ward-1, Chennai

In the result, the appeal of the assessee is allowed

ITA 1480/CHNY/2025[2016-17]Status: DisposedITAT Chennai30 Oct 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

For Appellant: Shri. G. Sitharaman, CA &For Respondent: Shri. R. Raghupathy, Addl. C.I.T
Section 11Section 12ASection 2(15)Section 250

failed to understand that the activities of the Appellant fall squarely within the scope of "education" as defined under Section 2(15) of the Act, which is an independent limb of the definition of "charitable purpose". However, the CIT(A) erroneously classified the Appellant's activities under "advancement ... other object of general public utility” only with the intent to attract the proviso to Section 2(15) of the Act, thereby unjustly denying the exemption otherwise available under Section 11 of the Act. 4. Without prejudice, even if the activities of the Appellant were to be considered as falling

Koolking Foundation, Malerkotla vs. The Commissioner of Income Tax (Exemptions), Chandigarh

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

ITA 882/CHANDI/2025[Not Applicable]Status: DisposedITAT Chandigarh29 Oct 2025

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 882 /Chd/2025 U/S 12Aa Kookling Foundation, The Cit बनाम C/O Kookling Udhyog Private (Exemptions), Limited, Chandigarh Vs. Village Ratolan, Focal Point, Dhuri Road, Malerkotla 148023 "थायी लेखा सं./ Pan No: Aaftk7048D अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Pankaj Bhalla, Ca (Virtual) राज"व क" ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 28.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 29.10.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 26.05.2025 Passed By The Ld. Commissioner Of Income Tax, Exemptions, Chandigarh.

For Appellant: Sh. Pankaj Bhalla, CA (Virtual)For Respondent: Sh. Manav Bansal, CIT DR
Section 124Section 12ASection 2(15)

omnibus in nature whereas the objects of the trust are well-defined, charitable in nature and aligned with the purposes enumerated under Section 2(15) of the Act. 882-Chd-2025 Koolking Foundation, Malerkotla 3 6. That the Ld. CIT (Exemptions) has wrongly interpreted the land purchase transaction

Arham Foundation, Pune vs. CIT (Exemption), Pune

In the result, appeal of the Assessee is allowed

ITA 1585/PUN/2025[2025-26]Status: DisposedITAT Pune29 Oct 2025AY 2025-26
Section 12ASection 33Section 36A

registered with the Charity Commissioner and has submitted Audited Financials before the Charity Commissioner as per Maharashtra Public Trust Act. 5.4 As per Section 2(15) of the Act, Charitable Purpose includes Education. Thus, Assessee's activities are as per the definition of Section 2(15) of the Act. This ... specific community/individuals. 8.1 Thus, we are of the opinion that objects and activities of the trust are charitable in nature as defined in Section 2(15) of the Act. As far as the issue of obtaining a meagre loan of Rs.1,15,800/- is concerned, it is observed that assessee