EDEN EDUCATION AND RESEARCH INSTITUTE ,AURANGABAD vs. CIT, EXEMPTION, , PUNE
In the result, the appeal of the Assessee stands Allowed
ITA 201/PUN/2021[-]Status: DisposedITAT Pune15 Mar 2022
Bench: Shri S.S.Viswanethra Ravi & Shri Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.201/Pun/2021 Eden Education & Research The Cit, Exemption, Institute, Vs Pune. Shop No.3, G.No.140, Delux Bazar, Satara, Aurangabad – 431001. Pan : Aaate 7724 P Appellant/ Revenue Respondent/ Assessee Assessee By Shri Kishor Phadke – Ar Revenue By Shri Naveen Gupta - Dr Date Of Hearing 15/02/2022 Date Of Pronouncement 15/03/2022 आदेश / Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order U/S 12Aa(1)(B)(Ii) Of The Income Tax Act, 1961 (‘The Act’) Passed By The Commissioner Of Income Tax (Exemption), Pune On 30.03.2021. 2) The Grounds Of Appeal Raised By Assessee Are As Under : “1. The Learned Cit, Exemption, Pune; Erred In Law & On Facts In Not Granting Registration U/S 12A Of The Ita, 1961 To Appellant Trust. 2. Appellant Contends That, Appellant Made Detailed Submissions Upon All The Issues Raised, Whereas, The Learned Cit, Exemption, Pune; Declined The Registration U/S 12A Of The Ita, 1961 On Altogether Erroneous & Incorrect Analogies Without Affording Any Further Opportunity To Appellant, To Make A Say In The Matter & As Such, Vitiated Principle Of Natural Justice. 3. The Learned Cit, Exemption, Pune Erred In Law & On Facts In Making Following Erroneous & Fallacious Observations: Eden Education & Research Institute (A)
Section 12ASection 131
68,433
24,78,699
12.00%
Thus, it is seen that the receipts from the activity are increased almost three fold in just 3 years from the start of the educational activity and the surplus by many folds. The applicant is generating a substantial surplus @ 12% to 15% from the activity. The fees structure include various components other than tuition
