SHRI MAHESH SEVA SAMITI ,AMRAVATI vs. INCOME TAX OFFICER WARD-3, AMRAVATI, AMRAVATI

Appeal is dismissed in above terms

Bench: Shri S. S. Godaraआयकर अपील सं. / Ita No.403/Nag/2017 िनधा"रण वष" / Assessment Year: 2010-11 Shri Mahesh Seva Samiti, Vs. Ito, Ward- 3, Amravati. Badnera Road, Amravati- 444601. Pan : Aaatm1457F Appellant Respondent Assessee By Shri Mahavir Atal : Revenue By : Shri G. J. Ninawe Date Of Hearing : 02.11.2022 Date Of Pronouncement : 29.12.2022 आदेश / Order Per S. S. Godara, Jm: This Assessee’S Appeal For Assessment Year 2010-11 Arises Against The Cit(A)-1, Nagpur’S Order Dated 28.09.2017 Passed In Case No. Cit(A)-1/508/2012-13, Involving Proceedings U/S 143(3) Of The Income Tax Act, 1961; In Short “The Act”. Heard Both The Parties. Case File Perused. 2. Coming To The Assessee’S Sole Substantive Grievance That Both The Learned Lower Authorities Have Erred In Law & On Facts In Denying Impugned Section 11 Exemption, It Is Noticed At The Outset

section 2(15) of the I.T. Act & facts of the case. Accordingly, assessment of appellant’s income at Rs.9,56,000/- is, hereby, confirmed. 5.0 In the result, the appeal is dismissed.” 3 3. Learned counsel has taken pains to file detailed written submissions reads as follows :- “The appellant is a public charitable trust having aims of education, medical

G. H. R. EDUCATION FOUNDATION ,NAGPUR vs. CIT EXEMPTION, PUNE

charitable organizations set up for advancement of objects of general public utility are entirely different from charities set up or established for the object of imparting education. In the case of the latter, the basis of exemption is Section 10(23C) (iiiab), (iiiad) and (vi). In all these provisions, the positive condition 'solely for educational purposes and the negative injunction

G.H.R. EDUCATION FOUNDATION,NAGPUR vs. CIT EXEMPTION, PUNE

In the result, assessee's appeal being ITA no

charitable\norganizations set up for advancement of objects of general public utility are\nentirely different from charities set up or established for the object of imparting\neducation. In the case of the latter, the basis of exemption is Section 10(23C)\n(iiiab), (iiiad) and (vi). In all these provisions, the positive condition 'solely for\neducational purposes and the negative