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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)

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

In the result, appeal of the Assessee is allowed

ITA 1584/PUN/2025[2025-26]Status: DisposedITAT Pune29 Oct 2025AY 2025-26

Bench: Shri Rama Kanta Panda & Shri Vinay Bhamoreआयकर अपऩल सं./Ita Nos.1584 & 1585/Pun/2025 निर्धारण वषा / Assessment Year :- Arham Foundation, V The Commissioner Of A-804, Swayambhau Hills S. Income Tax, Exemption, Society, Bibwewadi, Pune. Pune – 411037. Pan: Aafta8237Q Appellant/ Assessee Respondent / Revenue Assessee By Ca Prasad S. Bhandari Revenue By Shri Rakesh Jha – Cit(Dr) Date Of Hearing 15/10/2025 Date Of Pronouncement 29/10/2025 आदेश/ Order Per Vinay Bhamore, Jm: These Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Exemption), Pune Rejecting The Application For Grant Of Registration U/S.12A R.W.S 12Ab & 80G(5) Of The Income Tax Act, 1961(Hereinafter Referred To As „The Act‟) Both Dated 21.05.2025 Respectively. For The Sake Of Convenience, These Two Appeals Were Heard Together & Are Being

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

Kala Diksha, Chennai vs. CIT, Exmeptions, Chennai

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

ITA 2241/CHNY/2025[-]Status: DisposedITAT Chennai29 Oct 2025

Bench: Shri George George Kand Shri Jagadish

For Appellant: Shri Balasubramanian, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 12ASection 2(15)Section 80G

activities is in excess of threshold receipt of 20% of the total gross receipt. Therefore, CIT(E) concluded in light of proviso to section 2(15) of the Act, the assessee trust was not entitled to registration u/s.12AB of the Act. Accordingly, application of the assessee was rejected ... culture by educating the ancient / traditional dance culture to the students, which forms part of the education as per Section 2(15) of the Act. The relevant extract of the objects stated in the trust deed is given below: “To educate, promote and impart knowledge, practice and training

Maharashtra Industrial Development Corporation, Mumbai vs. Commissioner of Income-Tax (Exemptions), Mumbai

Accordingly, Ground No.3 raised by the Assessee is allowed for statistical purposes while all the other Grounds raised by the Assessee are dismissed having being rendered infructuous

ITA 6461/MUM/2025[2026-27]Status: DisposedITAT Mumbai29 Oct 2025AY 2026-27

Bench: SHRI OM PRAKASH KANT, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri V. Sridharan &For Respondent: Shri Paresh Deshpande
Section 12ASection 143(3)Section 2(15)

erred in holding that the activities carried on by the Appellant do not qualify the test 'charitable purpose' as defined in Section 2(15) of the Act. 3. That on the facts and circumstances of the case and in law, the impugned order is vitiated having been passed

DCIT, Exemption Circle, Ghaziabad vs. Hapur Pilukhuwa Development Authority, Hapur

ITA 3102/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Oct 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.Dcit Vs Hapur Pilukhuwa Development Cgo-2, Hapur Chungi, Authority, Preetvihar, Delhi Road, Ghaziabad, Uttar Pradesh Hapur, Uttar Pradesh Pan: Aaalh0051L Appellant Respondent Assessee By Dr. Kapil Geol, Adv Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/09/2025 Date Of Pronouncement 28/10/2025 Order Per Yogesh Kumar, U.S. Jm:

Section 11Section 2Section 2(15)

wherein benefit of section 11 of the Act was denied by the A.O. as per the amended provisions of section 2(15) of the Income Tax Act, 1961 ('Act' for short) vide order dated 28/12/2018. As against the assessment order dated 28/12/2018, the Assessee preferred an Appeal before ... activity of development and sale of properties and the aggregate value of receipts from the activities referred to in the first proviso of Section 2 (15) of the Act. Therefore, the Ld. CIT(A) committed error in allowing the Appeal of the Assessee, thus sought for allowing the Appeal

Care Today Fund, New Delhi vs. ITO Ward Exemption 1(3), Civic Centre New Delhi

In the result, the appeal of assessee is allowed

ITA 5734/DEL/2024[2017-18]Status: DisposedITAT Delhi27 Oct 2025AY 2017-18

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2017-18 Care Today Fund, Vs. Income Tax Officer, F-26, First Floor, Exemption 1(3), Connaught Place, New Delhi New Delhi-1100 01 Pan :Aaatc3762B (Appellant) (Respondent)

Section 11Section 11(2)Section 11(3)Section 12ASection 142(1)Section 143(2)Section 2(15)Section 250Section 80G(5)(vi)

activities of the assessee trust during the accounting period fall within the ambit of "Charitable purpose” as per the definition contained in Section 2(15) of the Act. So, the benefit of exemption of 3 ITA No. 5734/Del.2024 income under the provisions of Section 11 & 12 was being allowed

Sister Nivedita Mission Trust, Tenkasi vs. CIT(Exemption), Chennai

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

ITA 620/CHNY/2025[NIL]Status: DisposedITAT Chennai22 Oct 2025

Bench: Shri S.S. Viswanethra Ravi & Shri Ratnesh Nandan Sahayआयकर अपील सं./I.T.A. No.620/Chny/2025 Sister Nivedita Mission Trust, Vs. The Commissioner Of 121, Santhamoorthy Street, Income Tax (Exemption), Melapalayam Bazaar, Palayamkottai, Chennai. Tamil Nadu 627 005. [Pan:Aaets9316H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Vishwa Padmanabhan, C.A. ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 23.09.2025 घोषणा की तारीख /Date Of Pronouncement : 22.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.12.2024 Passed By The Ld. Commissioner Of Income Tax (Exemption), Chennai.

For Appellant: Shri K. Vishwa Padmanabhan, C.AFor Respondent: Shri R. Clement Ramesh Kumar, CIT
Section 12ASection 12A(1)(ac)Section 2(15)

holding that the activities of the trust cannot be held as education, relief of poor and ultimately charitable as defined in section 2(15) of the Act. 4. The ld. AR Shri K. Vishwa Padmanabhan, C.A. drew our attention to para 3 of the impugned order and submits that

M/S. Vijayanagar Educational Trust, Bengaluru vs. The Commissioner of Income Tax (Exemption), Bengaluru

In the result appeal of the assessee is allowed

ITA 2006/BANG/2019[2019-20]Status: DisposedITAT Bangalore22 Oct 2025AY 2019-20

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year: 2019-20

For Appellant: Shri Hariprasad Nayak, CAFor Respondent: Shri Murali Mohan, CIT(DR)(ITAT), Bengaluru
Section 11Section 115TSection 12ASection 13Section 133A

registered by the Income tax Authorities u/s 12 A of the act where in it is recorded that it satisfies the provision of section 2(15) of the act being charitable in nature., further it is assessed regularly for so many years i.e. from 1999 onwards till 2015 as charitable

Anandabava Seva Sanstha Gaushala Trust Jamnagar, Jamnagar vs. CIT(Exemption), Ahmedabad

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

ITA 31/RJT/2025[2024-25]Status: DisposedITAT Rajkot21 Oct 2025AY 2024-25

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 31/Rjt/2025 ("नधा"रणवष" / Assessment Year: (2024-25) (Hybrid Hearing) Anandbava Seva Sanstha Gaushala Trust, The Pr. Commissioner Of Income Vs. Gopal Bhuvan No, Anandbava Chakalo, Tax (E), Jamnagar 361001 Ahmedabad 380015 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaata2817K (Appellant) (Respondent) Appellant By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Sanjay Punglia, Ld. Sr. (Dr) Date Of Hearing : 22/07/2025 Date Of Pronouncement : 21/10/2025

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Sanjay Punglia, Ld. Sr. (DR)
Section 2(15)Section 80(5)Section 80GSection 80G(5)Section 80G(5)(iii)

benefit of public at large; such objects do not fall under the category of charitable objects as per the provision of section 2(15) of Income Tax Act, 1961. In these regard we wish to state that object mentioned in the notice is one of the object of the trust ... uplift and support those in need, regardless of their religious background, thereby fulfilling the true spirit of charitable work as envisioned under section 2(15) of the Income Tax Act, 1961. We acknowledge regarding the show cause for our application filed in Form 10AB under section

Thavam Research Foundation, Pudukkottai vs. CIT, Exemption, Chennai

ITA 1159/CHNY/2025[-]Status: DisposedITAT Chennai21 Oct 2025

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1159/Chny/2025

Section 12A(1)(ac)

Association supra Hon'ble High Court as held as under:- “....10.... If the case of the assessee falls in the first proviso to Section 2(15) of the Act, the benefit of registration which flow from Section 12A of the Act is not available. Anyhow, that is a matter

Shree Karadiya Rajput Samaj Baghi, Baghi-Paddhari vs. The Commissioner of Income Tax (Exemption), Ahmedabad

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

ITA 441/AHD/2025[N.A.]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : - Shree Karadiya Rajput Samaj Baghi, The Cit(Exemption) C/O. Sarda & Sarda (Ca) Vs. Vejalpur Ahmedabad. Sakar 1St Floor Dr. Radha-Krishnan Road Opp: Rajkumar College Rajkot. Pan : Aatts 3326 A (Applicant) (Responent) Assessee By : Shri Vimal Desai, Ar : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Vimal Desai, AR
Section 12ASection 12A(1)(ac)Section 2(15)

such a trust, whose benefits are confined to a specific caste or community, do not qualify as charitable within the meaning of section 2(15) of the Act, as the benefit is not for the public at large. 2.1 Based on the aforesaid observation, a show-cause notice dated ... reflected in its audited financial statements and audit report in Form No. 10BB, are in conformity with the charitable purposes defined under section 2(15) of the Act; and (iii) whether any expenditure has, in fact, been incurred for the benefit of a particular community or caste. 5.7 Upon such

Income Tax Officer Exemptions 2(4), Mumbai vs. The Chembur Gymkhana, Mumbai

Appeals of the revenue are allowed for

ITA 491/MUM/2025[2016-17]Status: DisposedITAT Mumbai16 Oct 2025AY 2016-17

Bench: Shri Narender Kumar Choudhry & Smt.Renu Jauhriआयकरअपीलसं./Ita No. 46, 47, 48 & 491/Mum/2025 ("नधा"रणवष" / Assessment Year: 2013-14, 2015-16,2016-17 & 2018-19) Income Tax Officer V/S. The Chembur Exemptions 2(4), Gymkhana बनाम Mumbai 16Th Road Chembur, Room No. 609, 6Th Floor, Mumbai 40071 Mtnl Building, Cumballa Hill, Mumbai 400026 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaatt4163F .. Appellant/अपीलाथ" Respondent/""तवाद"

For Appellant: Shri Vipul JoshiFor Respondent: 26.09.2025
Section 1Section 11Section 12ASection 13Section 13(1)Section 2(15)Section 250

object of 'general utilities carried on by the assessee in the present case are to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" and the assessee is not entitled to exemption u/s 11 because ... proviso to section 2(15) as the income of the assessee as spelt out clearly in the judgment of the Hon'ble Supreme Court ? 2. Whether on the facts and circumstances of the case and in law, and in the light of Civil Appeal No.21 762 of 2017 in various

Income Tax Officer Exemptions 2(4), Mumbai vs. The Chembur Gymkhana, Mumbai

Appeals of the revenue are allowed for

ITA 48/MUM/2025[2018-19]Status: DisposedITAT Mumbai16 Oct 2025AY 2018-19

Bench: Shri Narender Kumar Choudhry & Smt.Renu Jauhriआयकरअपीलसं./Ita No. 46, 47, 48 & 491/Mum/2025 ("नधा"रणवष" / Assessment Year: 2013-14, 2015-16,2016-17 & 2018-19) Income Tax Officer V/S. The Chembur Exemptions 2(4), Gymkhana बनाम Mumbai 16Th Road Chembur, Room No. 609, 6Th Floor, Mumbai 40071 Mtnl Building, Cumballa Hill, Mumbai 400026 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaatt4163F .. Appellant/अपीलाथ" Respondent/""तवाद"

For Appellant: Shri Vipul JoshiFor Respondent: 26.09.2025
Section 1Section 11Section 12ASection 13Section 13(1)Section 2(15)Section 250

object of 'general utilities carried on by the assessee in the present case are to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" and the assessee is not entitled to exemption u/s 11 because ... proviso to section 2(15) as the income of the assessee as spelt out clearly in the judgment of the Hon'ble Supreme Court ? 2. Whether on the facts and circumstances of the case and in law, and in the light of Civil Appeal No.21 762 of 2017 in various

Income Tax Officer Exemptions 2(4), Mumbai vs. The Chembur Gymkhana, Mumbai

Appeals of the revenue are allowed for

ITA 47/MUM/2025[2015-16]Status: DisposedITAT Mumbai16 Oct 2025AY 2015-16

Bench: Shri Narender Kumar Choudhry & Smt.Renu Jauhriआयकरअपीलसं./Ita No. 46, 47, 48 & 491/Mum/2025 ("नधा"रणवष" / Assessment Year: 2013-14, 2015-16,2016-17 & 2018-19) Income Tax Officer V/S. The Chembur Exemptions 2(4), Gymkhana बनाम Mumbai 16Th Road Chembur, Room No. 609, 6Th Floor, Mumbai 40071 Mtnl Building, Cumballa Hill, Mumbai 400026 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaatt4163F .. Appellant/अपीलाथ" Respondent/""तवाद"

For Appellant: Shri Vipul JoshiFor Respondent: 26.09.2025
Section 1Section 11Section 12ASection 13Section 13(1)Section 2(15)Section 250

object of 'general utilities carried on by the assessee in the present case are to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" and the assessee is not entitled to exemption u/s 11 because ... proviso to section 2(15) as the income of the assessee as spelt out clearly in the judgment of the Hon'ble Supreme Court ? 2. Whether on the facts and circumstances of the case and in law, and in the light of Civil Appeal No.21 762 of 2017 in various

Income Tax Officer Exemptions 2(4), Mumbai vs. The Chembur Gymkhana, Mumbai

Appeals of the revenue are allowed for

ITA 46/MUM/2025[2013-14]Status: DisposedITAT Mumbai16 Oct 2025AY 2013-14

Bench: Shri Narender Kumar Choudhry & Smt.Renu Jauhriआयकरअपीलसं./Ita No. 46, 47, 48 & 491/Mum/2025 ("नधा"रणवष" / Assessment Year: 2013-14, 2015-16,2016-17 & 2018-19) Income Tax Officer V/S. The Chembur Exemptions 2(4), Gymkhana बनाम Mumbai 16Th Road Chembur, Room No. 609, 6Th Floor, Mumbai 40071 Mtnl Building, Cumballa Hill, Mumbai 400026 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaatt4163F .. Appellant/अपीलाथ" Respondent/""तवाद"

For Appellant: Shri Vipul JoshiFor Respondent: 26.09.2025
Section 1Section 11Section 12ASection 13Section 13(1)Section 2(15)Section 250

object of 'general utilities carried on by the assessee in the present case are to be covered under residuary part of section 2(15) as "advancement of any other object of general public utility" and the assessee is not entitled to exemption u/s 11 because ... proviso to section 2(15) as the income of the assessee as spelt out clearly in the judgment of the Hon'ble Supreme Court ? 2. Whether on the facts and circumstances of the case and in law, and in the light of Civil Appeal No.21 762 of 2017 in various

Jan Kalyan Samiti, Patna vs. CIT Exemption, Patna

In the result, both the appeals of the assessee, being ITA Nos

ITA 88/PAT/2025[2022-2023]Status: DisposedITAT Patna15 Oct 2025AY 2022-2023

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.80 & 88/Pat/2025 Assessment Year: 2022-23 Jan Kalyan Samiti…………..….………. …………………....Appellant Khasmahal, Road No.3, Chiraiyatand, Patna – 800001. [Pan: Aaatj5412D] Vs. Cit (Exemption), Patna....…..……………..………………….…..... Respondent Appearances By: Shri Anjan Biswas, Fca, Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 13, 2025 Date Of Pronouncing The Order : October 15, 2025 आदेश / Order Per Sonjoy Sarma: Both These Appeals By The Assessee Are Directed Against The Orders Of The Learned Commissioner Of Income Tax (Exemption), Patna, Dated 26.12.2024, For The Assessment Year 2022–23. Since The Issues Involved In Both The Appeals Pertain To The Same Assessee & Arise Out Of Common Facts & Connected Applications, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. Ita No. 88/Pat/2025 Relates To Rejection Of The Application In Form No. 10Ab Filed By The Assessee Seeking Regular Registration Under Clause (Ac)(Iii) Of Sub-Section (1) Of Section 12A Of The Income-Tax Act, 1961 & Ita No. 80/Pat/2025 Relates To Rejection Of The Application In

Section 11Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)

have been carried out in accordance with the objects of the society for charitable purposes within the meaning of section 11 read with section 2(15) of the Act. Accordingly, the application in Form 10AB seeking regular registration under section 12A(1)(ac)(iii) and the corresponding application under section

Jan Kalyan Samiti, Patna vs. CIT Exemption, Patna

In the result, both the appeals of the assessee, being ITA Nos

ITA 80/PAT/2025[2022-23]Status: DisposedITAT Patna15 Oct 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.80 & 88/Pat/2025 Assessment Year: 2022-23 Jan Kalyan Samiti…………..….………. …………………....Appellant Khasmahal, Road No.3, Chiraiyatand, Patna – 800001. [Pan: Aaatj5412D] Vs. Cit (Exemption), Patna....…..……………..………………….…..... Respondent Appearances By: Shri Anjan Biswas, Fca, Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 13, 2025 Date Of Pronouncing The Order : October 15, 2025 आदेश / Order Per Sonjoy Sarma: Both These Appeals By The Assessee Are Directed Against The Orders Of The Learned Commissioner Of Income Tax (Exemption), Patna, Dated 26.12.2024, For The Assessment Year 2022–23. Since The Issues Involved In Both The Appeals Pertain To The Same Assessee & Arise Out Of Common Facts & Connected Applications, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. Ita No. 88/Pat/2025 Relates To Rejection Of The Application In Form No. 10Ab Filed By The Assessee Seeking Regular Registration Under Clause (Ac)(Iii) Of Sub-Section (1) Of Section 12A Of The Income-Tax Act, 1961 & Ita No. 80/Pat/2025 Relates To Rejection Of The Application In

Section 11Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)

have been carried out in accordance with the objects of the society for charitable purposes within the meaning of section 11 read with section 2(15) of the Act. Accordingly, the application in Form 10AB seeking regular registration under section 12A(1)(ac)(iii) and the corresponding application under section

Haji Pir Mohmad Yusuf Waqf, Surat vs. CIT(Exemption), Ahmedabad

In the result, appeal of the assessee is dismissed

ITA 1326/SRT/2024[2024-25]Status: DisposedITAT Surat15 Oct 2025AY 2024-25

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1326/Srt/2024 (Hybrid Hearing) Haji Pir Mohmad Yusuf Waqf Commissioner Of Income-Tax बनाम/ Chowk Bazar, Surat- 395 003 (Exemption), Ahmedabad-380 015 Vs. "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacth 6551 R (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Suresh K. Kabra, Ca राज" की ओर से /Respondent By Shri Ravi Kant Gupta, Cit-Dr सुनवाई की तारीख/Date Of Hearing 30/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 15/10/2025

Section 11Section 12ASection 12A(1)(ac)Section 13(1)(b)Section 2(15)

IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI DINESH MOHAN SINHA, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT

Deputy Commissioner of Income Tax, New Delhi vs. Odia Samaj, New Delhi

In the result Cross objections raised by assessee is allowed

ITA 5638/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 12ASection 133(6)Section 143(3)Section 144BSection 194CSection 194JSection 2(15)Section 80G

erred in allowing and directing the AO to re- compute to what extent exemption can be awarded under second proviso to section 2(15), by referring the Hon’ble Apex Court order in the case of Ahmedabad Urban Development Authority. (2) The appellant craves leave to add, to alter ... AO/CIT(A) erred in not appreciating that the case of the Assessee is not hit by the second proviso to section 2(15) of the Act. 3. That on facts and circumstances of the case and in law the AO/CIT(A) erred in not appreciating that the application of receipts

Gyan Devi Memorial Cultural & Educational Society, New Delhi vs. CIT(E), New Delhi

In the result, appeal of the assessee is allowed

ITA 1303/DEL/2020[-]Status: DisposedITAT Delhi15 Oct 2025

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : Nil] Gyan Devi Memorial Cultural & Vs Cit(Exemption), Educational Society, New Delhi-110002. F-26, Bali Nagar, Delhi-110015 Pan-Aaate8521G Appellant Respondent Appellant By Shri Nishant Gupta, Ca Respondent By Ms.Monika Singh, Cit Dr Date Of Hearing 17.07.2025 Date Of Pronouncement 15.10.2025 Order

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

Trust is primarily engaged in providing Primary education to the poor and needy children of the society as defined in the 'Charitable Activities' section 2(15) of the Act. Hence, the Ld. CIT(E) erred in facts and on law in treating the activities of the trust as non-genuine

Printech Park Cluster Bangalore, Bengaluru vs. Commissioner of Income Tax (Exemptions), Bengaluru

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

ITA 1065/BANG/2025[2025-26]Status: DisposedITAT Bangalore14 Oct 2025AY 2025-26

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K.Assessment Year : 2025-26

For Appellant: Shri Kupendra Setty, CAFor Respondent: Shri Murali Mohan M, CIT-DR
Section 12A

from the participation of their Page 5 of 12 members only, such an organisation would not fall under the purview of proviso to section 2(15). The AO further held that the activity of developing the land and distribution of plots to the members / non-members are not defined ... benefits of the activities would not be open to the general publics and therefore the same is hit by the provisions of section 2(15) of the Act. Therefore the AO had concluded that the assessee’s application for renewal of registration as a charitable organisation