ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS) vs. AHMEDABAD URBAN DEVELOPMENT AUTHORITY

Bench: HON'BLE THE CHIEF JUSTICE

10a. It is clear on a plain natural construction of the language used by the legislature that the ten crucial words “not involving the carrying on of any activity for profit” go with “object of general public utility” and not with “advancement”. It is the object of general public utility which must not involve the carrying on of any activity

M/S NEW NOBLE EDUCATIONAL SOCIETY vs. THE CHIEF COMMISSIONER OF INCOME TAX 1

The appeals are hereby dismissed, without order on costs

Bench: HON'BLE THE CHIEF JUSTICE

Housing Societies Ltd., [2003] 6 ALT 62 (AP)). 5 23. Imparting of education is regarded as an activity that is charitable in nature. Education has so far not been regarded as a trade or business where profit is the motive. (State of Bombay v. R.M.D. Chamarbaugwala, AIR 1957 SC 699; T.M.A. Pai Foundation v. State of Karnataka