ITO 19(3)(2), MUMBAI vs. INDIAN CORPORATE LOAN SECURITIZATION TRUST 2008 SERIES 14I, MUMBAI

In the result, Revenue’s appeal for A

Bench: Shri Jason P. Boaz & Shri Sandeep Goasinindian Corporate Loan Securitisation Income Tax Officer-9(3)(2) Trust- 2008 Series 14 Mumbai C/O. Il & Fs Trust Co. Ltd. Vs. 10Th Floor, “G” Block, Bkc Bandra (E), Mumbai 400051 Pan – Aaati6786P Appellant Respondent Income Tax Officer-(23)1)(2) Indian Corporate Loan [Erstwhile Ito-19(3)(2)] Securitisation Trust- 2008 Series 14 Room No. 108, Matru Mandir Vs. C/O. Il & Fs Trust Co. Ltd. Tardeo Road, Grant Road 10Th Floor, “G” Block, Bkc Mumbai 400007 Bandra (E), Mumbai 400051 Pan – Aaati6786P Appellant Respondent

234 ITR 188 (SC) at S. No. 7 of Assessee's Legal Compilation Box File No. 1 ii. Sancheti Leasing Co. Ltd. vs. ITO 246 ITR 814 (Mad.) at S. No. 5 of Assessee's Legal Compilation Box File No. 1 Reliance was also placed on the decision in the case of DHFL Venture Capital Fund vs. ITO (ITAT

ADITYA BIRLA EDUCATION TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

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

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjee

section 11 of the Act is reproduced in summarized as below: “………………… 2.1.2 At the outset, the Assessee humbly states that it carries on various education programmes through its verticals / units as mentioned above. The said education programmes are carried in India. As such, the charitable activities are confined in India and none of the activities are carried outside India

DCIT (E) 2(1), MUMBAI vs. MUMBAI RAILWAY VIKAS CORPN LTD, MUMBAI

charitable purpose' also includes the activity of 'advancement of any other object of general public utility'. According to the Revenue, even if the activities are to be considered as falling within the scope of Sec. 2(15) of the Act, it fits into the said expression 'advancement of any other object of general public utility'. The proviso

DCIT CENT. CIR.1(4), MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION & SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR 1(40, MUMBAI vs. PODAR EDUCATION AND SPORTS TRUSTS, BENGALURU

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR1(4) , MUMBAI vs. PODAR EDUCATION AND SPORTS TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4), MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT CENT. CIR 1(4) , MUMBAI vs. PODAR EDUCATION TRUST, MUMBAI

Accordingly, all 11 appeals filed by the learned assessing officer are dismissed

Bench: Shri Amit Shukla, Jm & Shri Prashant Maharishi, Am

charitable trust registered under Section 12AA (1) (b) (i) of The Income-tax Act, 1961 (the Act) from 3 January 2006 as per registration granted by the Director of Income tax (Exemption), Bangalore. 07. During the year, assessee has earned income from educational activities as well as interest income. Assessee filed return of income under Section

DCIT (E) 2(1), MUMBAI vs. MUMBAI RAILWAY VIKAS CORPN LTD, MUMBAI

In the result, all the Four appeals filed by the revenue and four cross objections filed by the assessee are dismissed

Bench: Shri Rajesh Kumar & Shri Pavan Kumar Gadale

Trust vs. CIT, 101 ITR 234 (SC) to contend that the word 'education' should not be confined only to scholastic instructions, but other forms of education are also included in the expression 'education'. Though the decision of the Hon'ble Gujarat High Court is in the context of Sec. 10(22) of the Act, yet, it is of relevance

DCIT (E) 2(1), MUMBAI vs. MUMBAI RAILWAY VIKAS CORPN LTD, MUMBAI

charitable purpose' also includes the activity of 'advancement of any other object of general public utility'. According to the Revenue, even if the activities are to be considered as falling within the scope of Sec. 2(15) of the Act, it fits into the said expression 'advancement of any other object of general public utility'. The proviso

DCIT (E) 2(1), MUMBAI vs. MUMBAI RAILWAY VIKAS CORPN LTD, MUMBAI

charitable purpose' if it involves carrying on of any activity in the nature of trade, commerce or business or any activity of rendering any service in relation to any trade, commerce or business for a cess or fee or any other consideration irrespective of the nature of use or application or retention of the income from such activity. By relying

MEHLI MEHTA MUSIC FOUNDATION,MUMBAI vs. ITO, EXEMPTION WARD-2(4), MUMBAI

Trust v. CIT (1975) 101 ITR 234 (SC)/[1976] 1 SCC 254 in the\nfollowing terms:\n\"5. The sense in which the word \"education\" has been used in section 2(15)\nis the instruction, schooling or training given to the young in preparation for\nthe work of life. It also connotes the whole course of scholastic instruction\nwhich