3 results for “disallowance”+ Section 12A(2)clear
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In the result, this appeal of assessee is allowed
Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay
2) The predominant object test must be applied - the purpose of education should not be submerged by a profit-making motive. (3) A distinction must be drawn between the making of a surplus and an institution being carried on "for profit". No inference arises that merely because imparting education results in making a surplus, it becomes an activity for profit