Section 12A of the Income Tax Act

Income-tax Act, 2025: ss.332–355

Section 12A of the Income-tax Act, 1961 corresponds to sections 332 to 355 of the Income-tax Act, 2025, the provisions on registered non-profit organisations.

Read the 2025 provisions

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 12A is CIT v. Institute of Banking Personnel Selection (264 ITR 110), cited in 398 of the 6,064 judgments on BharatTax that turn on this section.

Leading authorities on Section 12A

CIT v. Institute of Banking Personnel Selection
264 ITR 110 · 2003 · High Court
398
citing judgments

Depreciation is allowable on assets for which the cost has been fully allowed as an application of income under Section 11 in previous years, when computing the income of a charitable trust. Charitable trusts are also entitled to carry forward their deficit.

ACIT v. Ahmedabad Urban Development Authority
143 Taxmann.com 278 · 2022 · Supreme Court
390
citing judgments

If activities for the advancement of general public utility are carried on as a business, income from such activities is not exempt under Section 11, even if the profits are utilized for the main charitable object. The argument that profits from general public utility activities can be ploughed back to charity to maintain exemption is not a good law.

Addl. CIT v. Surat Art Silk Cloth Manufacturers Association
121 ITR 1 · 1980 · Supreme Court
328
citing judgments

A charitable institution, whose predominant object is general public utility, can engage in non-charitable activities yielding incidental profits, provided these profits are deployed to achieve the dominant charitable object. A subsidiary object, if ancillary to the primary charitable purpose, does not negate the institution's charitable character.

Sole Trustee, Loka Shikshana Trust v. CIT
101 ITR 234 · 1975 · Supreme Court
323
citing judgments

This case defines 'education' under Section 2(15) of the Income Tax Act as systematic instruction, schooling, or training given to the young for preparation for the work of life. It clarifies that 'education' in this context has a narrow meaning, not extending to every acquisition of further knowledge.

Exide Industries Ltd. v. Union of India
292 ITR 470 · 2007 · High Court
320
citing judgments

The Calcutta High Court held that restricting deduction for leave encashment via Section 43B(f) was arbitrary and contrary to Supreme Court decisions. However, this judgment was later stayed by the Supreme Court.

Escorts Ltd. v. UOI
199 ITR 43 · 1993 · Supreme Court
267
citing judgments

A statute should not be construed to permit double deduction for the same expenditure unless specifically provided by law.

1. AIR 1951 SC 467: HARLA v. THE STATE OF RAJASTHAN. 2
2 SCC 453 · 1997 · Reported
222
citing judgments

When an appeal or revision is filed against an order passed by a subordinate forum, and a superior forum modifies, reverses, or affirms that decision, the order of the subordinate forum merges into the superior forum's decision, which then becomes the sole operative and enforceable order.

CIT v. Shri Plot Swetamber Murti Pujak Jain Mandal
211 ITR 293 · 1995 · High Court
204
citing judgments

A charitable trust can carry forward its excess expenditure from previous years and adjust it against the income of subsequent years, which qualifies as an application of income under Section 11. Additionally, voluntary contributions received for a specific purpose are treated as corpus funds and are not taxable.

CIT v. Gujarat Oil & Allied Industries
201 ITR 325 · 1993 · High Court
195
citing judgments

The requirement to file an audit report along with the income tax return, as specified in provisions like Section 80J(6A) or 80-IA(7), is directory and not mandatory. Substantial compliance is achieved if the audit report is submitted at any time before the assessment is framed or completed, and benefits should not be denied merely due to a delay in furnishing it.

CIT v. Society of the Sisters of St. Anne
146 ITR 28 · 1984 · High Court
195
citing judgments

Depreciation claimed by a charitable trust on its assets is an allowable application of income for computing exemption under Section 11, and this does not constitute a double deduction.

Judgments on Section 12A

Shri Maheshwari Jankaiyan Trust, Indore vs. The CIT Exemption, Bhopal

In the result, the appeal filed by the Assessee is allowed

ITA 123/IND/2022[2017-18]Status: DisposedITAT Indore17 Apr 2023AY 2017-18

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri B.M. Biyani (Accountant Member)

Section 11(1)(a)Section 12ASection 2(15)Section 263Section 80G

Dy. Commissioner of Income Tax (Exemption)-1(1), Mumbai vs. Kohinoor Education Trust, Mumbai

ITA 2900/MUM/2022[2016-2017]Status: DisposedITAT Mumbai13 Apr 2023AY 2016-2017
For Appellant: Shri Samir ShahFor Respondent: Ms. Samruddhi Hande
Section 11(6)Section 12ASection 143(3)

Indian Red Cross Society vs. Deputy Commissioner of Income Tax

WP(C)/31520/2022HC Kerala12 Apr 2023
Section 12ASection 143Section 143(1)Section 154

Central Charitable Trust, Jafarpur vs. Income Tax Officer, Exemption Ward, Varanasi

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 12/VNS/2023[2014-2015]Status: DisposedITAT Varanasi12 Apr 2023AY 2014-2015

Bench: Shri Ramit Kochar & Shri Pavan Kumar Gadalecentral Charitable Trust Vs. Income Tax Officer Jafrapur- 276001, Exemption, Uttar Pradesh. Wardayakarbhawan, Maqboolalam Road, Varanasi 221002 Uttar Pradesh Pan/Gir No. : Aabtc4875G Appellant .. Respondent Appellant By : Shriarvind Shukla, Advocate Respondentby : Shri A.K. Singh, Sr.Dr Date Of Hearing 12.04.2023 Date Of Pronouncement 12.04.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi/Cit(A)Passed U/S.250 Of The Income Tax Act, 1961.The Assessee Has Raised The Following Grounds Of Appeal: Central Charitable Trust “1. Because The Learned Cit(A) Has Erred In Law As Well As On Facts In Dismissing The Appeal Of The Trust Running Educational Institution Without Appreciating The Facts & Circumstances Of The Case In The Correct Perspective. 2. Because The Learned Ao As Well As The Learned Cit(A) Have Failed To Appreciate That The Assessee Is Engaged Solely In Running An Educational Institution Having Gross Receipts Below One Crore & Hence No Part Of His Receipts/Income Was Taxable By Virtue Of Clear Unambiguous Provisions Of Section 10(232)(Iiiad). 3. Because The Authorities Below Have Sought To Deny The Benefit Available To The Educational Institution By Clear Provisions Of Section 10(23C)(Iiiad) With Unrelated Provisions Of Section 11/12A When Such Sections Should Not Be Applied To The Facts Of The Case. 4. Because The Authorities Below Have Sought To Deny The Benefit Available To The Educational Institution On The Basis Of Some Inadvertent Technical Errors In Filing Return Without Appreciating The Facts Of The Case. 5. Because The Order Is Bad In Law As Well As On Facts.”

For Appellant: ShriArvind Shukla, AdvocateFor Respondent: Shri A.K. Singh, Sr.DR
Section 10Section 10(232)(iiiad)Section 10ASection 11Section 12ASection 143(1)Section 250

Dolphin Educational Foundation, Madurai vs. The Income Tax Officer(Exemptions), Madurai

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 76/CHNY/2023[--]Status: DisposedITAT Chennai31 Mar 2023

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 76/Chny/2023 Dolphin Educational Foundation, Income Tax Officer 43, Harveynagar, 2Nd Street, V. (Exemptions), Arasaradi, Madurai. Chennai. [Pan: Aactd-2565-K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. G. Baskar, Advocate ""यथ" क" ओर से/Respondent By : Shri. M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 29.03.2023 घोषणा क" तारीख/Date Of Pronouncement : 31.03.2023

For Appellant: Shri. G. Baskar, AdvocateFor Respondent: Shri. M. Rajan, CIT
Section 12A

Green Educational Charitable Trust, Muzaffarnagar vs. CIT(E), Lucknow

In the result, the appeal of Assessee is allowed

ITA 399/DEL/2021[2020-21]Status: DisposedITAT Delhi31 Mar 2023AY 2020-21

Bench: Sh. Anil Chaturvedi & Sh. Narender Kumar Choudhrym/S. Green Educational Vs. Cit(Exemption) Charitable Trust, 5Th Floor, South Block, Hindan River Bridge, T. C.46V, Up State Main Road, Budhana Construction & Infrastructure Development Corporation, Vibhuti Khand, Gomti Pan No. Aadtg 0004 H Nagar, Lucknow (Appellant) (Respondent) Assessee By --None- Revenue By Ms. Sapna Bhatia, Cit-D.R. Date Of Hearing: 01.02.2023 Date Of Pronouncement: 31.03.2023 Order Per Anil Chaturvedi, Am : This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.02.2021 Of The Commissioner Of Income Tax (Exemption), Lucknow Relating To Assessment Year 2020-21. 2. Brief Facts Of The Case As Culled Out From The Material On Record Are As Under :- M/S. Green Educational Charitable Trust Vs. Cit 2

Section 12A

Sam Women Upliftment Trust, Chennai vs. CIT (Appeals)-NFAC, Delhi, NFAC

In the result, appeal of the assessee is allowed

ITA 19/CHNY/2023[2019-2020]Status: DisposedITAT Chennai30 Mar 2023AY 2019-2020

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.No.19/Chny/2023 ("नधा"रणवष" / Assessment Year: 2019-20) Sam Women Upliftment Trust, Vs The Adit., 5/3, Periamalaiappan Street, Centralized Processing Center, Royapettah, Chennai-600 014. Bengaluru. Pan: Aakts 1966 R (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. P.Sajit Kumar, JCITFor Respondent: 30.03.2023
Section 11Section 119(2)Section 119(2)(b)Section 12ASection 143(1)Section 154

DCIT, Exemption Circle, Patna vs. Bijendra Memorial Society, Patna

In the result, the appeal is allowed

ITA 3/PAT/2021[2015-16]Status: DisposedITAT Patna29 Mar 2023AY 2015-16

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.3/Pat/2021 Assessment Year: 2015-16 Dcit (Exemption), Circle-Patna........……….........…..........….…… Appellant Vs. Bijendra Memorial Society….....….....……........…...…...…..…..... Respondent 404 Shyam Centre, Exhibition Road, Patna-800001. [Pan:Aabtb1511G] Appearances By: Shri Soumitra Choudhury, Adv., Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 01, 2023 Date Of Pronouncing The Order : March 29, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Revenue Against The Order Dated 28.08.2020 Of The Commissioner Of Income Tax (Appeals)-1, Patna [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Revenue In This Appeal Has Taken The Following Grounds Of Appeal: “1. The Ld.Cit(A) Has Erred In Law As Well As Facts Of The Case In Deleting The Additions Of Disallowances Towards The Salary/Remuneration Of Rs. 17,40,000/- & Rs.12,60,000/- Paid To Treasurer & Secretary Of The Trust & Rs.3,00,000/- To Shri Kala Choudhary For Hiring Of Bus & Rs.8,40,000/- For Hostel Building Rent To M/S Aadya Bhasker Enterprises Private Limited From The Income Of Trust Which Were Found Excessive & Unreasonable Under Sub-Section (3) Of Section 13 Of The

Section 12ASection 13Section 13(3)Section 143(3)Section 250

Shivani Foundation, Delhi vs. CIT(E), Delhi

In the result, the appeal of the assessee is allowed for statistical purposes ex-parte

ITA 9574/DEL/2019[-]Status: DisposedITAT Delhi29 Mar 2023

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 12ASection 80GSection 80G(5)(vi)

Shivani Foundation, New Delhi vs. CIT Exemptions, Delhi

In the result, the appeal of the assessee is allowed for statistical purposes ex-parte

ITA 9020/DEL/2019[2019-20]Status: DisposedITAT Delhi29 Mar 2023AY 2019-20

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: NoneFor Respondent: Shri H.K. Chaudhary, CIT-DR
Section 12ASection 80GSection 80G(5)(vi)

Dr. Shivajirao Jondhale Reseatrch Foundation, Mumbai vs. CIT, Exemption, Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 3228/MUM/2022[2022-2023]Status: DisposedITAT Mumbai28 Mar 2023AY 2022-2023

Bench: Shri Om Prakash Kant & Shir Pavan Kumar Gadaledr. Shivajirao Jondhale Vs. Cit (Exemption) Research Foundation, No. 322, 3Rd Floor, Mahatma Phule Road, Ito, Pmt, Bldg, Kalyan, Vishnunagar Shankar Seth Road, S.O, Thane-421202 Pune-411037 Maharashtra. Maharashtra. Pan/Gir No. : Aadtd6635R Appellant .. Respondent Appellant By : Mr.Tanzil R Padvekar.Ar Respondent By : Ms.Neerja Sharma.Dr Date Of Hearing 15.02.2023 Date Of Pronouncement 17.02.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Exemptions), Pune Passed U/Sec12Ab(1)(B) Of The Act Dated 27.10.2012. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Mr.Tanzil R Padvekar.ARFor Respondent: Ms.Neerja Sharma.DR
Section 12ASection 12A(1)(ac)

Light Associates Ministry of St. Barnaba Society, Khammam vs. ITO, (Exemptions)-3, Hyderabad

In the result, appeal filed by the assessee is partly allowed for statistical purposes

ITA 305/HYD/2021[2010-11`]Status: DisposedITAT Hyderabad27 Mar 2023

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2010-11 Light Associates Ministry Vs. Income Tax Officer Of St. Barnaba Society (Exemptions)-3 Khammam Hyderabad Pan:Aaatl4330L (Appellant) (Respondent) Assessee By: Advocate B. Nishitha Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 17/03/2023 Date Of Pronouncement: 27/03/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 2.12.2019 Of The Learned Cit (A)-9 Hyderabad, Relating To A.Y.2010-11. 2. There Is A Delay Of 490 Days In Filing Of This Appeal By The Assessee For Which The Assessee Has Filed A Condonation Application Explaining The Reasons For Such Delay Which Is Due To The Prevailing Covid Situation. After Hearing Both The Sides, The Delay In Filing Of The Appeal By The Assessee Is Condoned & The Appeal Is Admitted For Adjudication.

For Appellant: Advocate B. NishithaFor Respondent: Shri Rajendra Kumar, CIT(DR)
Section 11Section 12ASection 143(2)Section 143(3)Section 144Section 148

Late Shantaben Chandrashankar Vyas Charitable Trust, Rajkot vs. The Deputy Commissioner of Income Tax, (CPC), Bangalore

In the result, the appeal of the assesse is hereby dismissed

ITA 25/RJT/2022[2018-19]Status: DisposedITAT Rajkot24 Mar 2023AY 2018-19

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyalआयकर अपील सं./Ita No.25/Rjt/2022 िनधा"रण िनधा"रण वष" िनधा"रण िनधा"रण वष" वष"/Asstt. Years: 2018-2019 वष"

For Appellant: Shri J.R. Mankodi, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R
Section 11Section 12ASection 12A(1)Section 12A(2)Section 143(1)

Indian Red Cross Society Hanamkonda, Warangal vs. ITO, Exemption Ward-1(4), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 112/HYD/2023[2016-17]Status: DisposedITAT Hyderabad23 Mar 2023AY 2016-17

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2016-17 Indian Red Cross Society, Vs. Income Tax Officer Hanamkonda, Warangal (Exemption) Pan:Aabii2634P Ward 1(4) Hyderabad (Appellant) (Respondent) Assessee By: Shri K.V. Chalamaiah, Ca Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 20/03/2023 Date Of Pronouncement: 23/03/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated16.12.2022 Of The Learned Cit (A)-Nfac, Relating To A.Y.2016-17. 2. This Is The 2Nd Round Of Litigation Before The Tribunal. Facts Of The Case, In Brief, Are That The Assessee Is A Trust & Filed Its Return Of Income Declaring ‘Nil’ Income After Claiming Exemption U/S 11 Of The I.T. Act. The Case Was Selected For Scrutiny & The Assessment Was Completed On 20.12.2018 At An Assessed Income Of Rs.15,08,580/-.

For Appellant: Shri K.V. Chalamaiah, CAFor Respondent: Shri Kumar Aditya, DR
Section 11Section 12A

Itw India Gratuity Fund, Gurgaon, Haryana vs. ACIT, Exemption Circle-1(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 105/HYD/2023[2014-15]Status: DisposedITAT Hyderabad20 Mar 2023AY 2014-15

Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year: 2014-15 Itw India Gratuity Fund, Vs. A.C.I.T. Exemption Gurgaon, Haryana Ward-1(1) Pan:Aaati5254L Hyderabad (Appellant) (Respondent) Assessee By: Shri Surya Kiran Motamarri, Ca Revenue By: Shri Kumar Aditya, Dr Date Of Hearing: 16/03/2023 Date Of Pronouncement: 20/03/2023 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.12.2022 Of The Learned Cit (A)-Nfac, Relating To A.Y.2014-15. 2. Facts Of The Case, In Brief, Are That The Assessee Aop Is An Approved Gratuity Fund Trust Recognized By The Commissioner Of Income Tax. The Assessee Filed Its Return Of Income In Form Itr- 7 By Mentioning That Its Income Is Exempt U/S. 10(23C) (Iv) & That It Erroneously Mentioned In The Tax Return That It Was Granted Registration Under Section 12A. The Books Of Accounts Were Audited As Per The Normal Accounting Practice. Even In The Itr 7 Filed By The Assessee, It Was Erroneously Mentioned That Page 1 Of 6

For Appellant: Shri Surya Kiran Motamarri, CAFor Respondent: Shri Kumar Aditya, DR
Section 10Section 10(25)Section 12ASection 143(1)Section 154

Ek Ka Josh Foundation, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result we set aside the order of Ld

ITA 2840/MUM/2022[2022-2013]Status: DisposedITAT Mumbai20 Mar 2023AY 2022-2013

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: Sh. Punit Shah / Sh. Mehli M. GolwlaFor Respondent: Sh. Solgy Jose, CIT-DR
Section 12ASection 8

Ek Ka Josh Foundation, Mumbai vs. Commissioner of Income Tax (Exemption), Mumbai

In the result we set aside the order of Ld

ITA 2839/MUM/2022[2022-23]Status: DisposedITAT Mumbai20 Mar 2023AY 2022-23

Bench: Shri Vikas Awasthy & Shri Gagan Goyal

For Appellant: Sh. Punit Shah / Sh. Mehli M. GolwlaFor Respondent: Sh. Solgy Jose, CIT-DR
Section 12ASection 8

Swami Vivekananda Karma Tirtha, Kolkata vs. ITO, Ward-44(1), Kolkata

In the result, the appeal of the assessee stands allowed

ITA 12/KOL/2022[2019-20]Status: DisposedITAT Kolkata14 Mar 2023AY 2019-20

Bench: Shri Sanjay Gargi.T.A. No.12/Kol/2022 Assessment Year: 2019-20 Swami Vivekananda Karma Tirtha......…..........…..................….…… Appellant 46, Camal West Road, Ultadanga, Kolkata - 700004. [Pan:Aawts0391Q] Vs. Ito, Ward-44(1), Kolkata...…..………....……........…...…...…..…..... Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Smt. Ranu Biswas, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 14, 2023 Date Of Pronouncing The Order : March 14, 2023 आदेश / Order The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 19.11.2021 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Sole Issue Involved In This Appeal Is Whether The Assessee Is Entitled To Exemption U/S 11 R.W.S 12A Of The Act In Respect Of Assessment Year, The Assessment Proceedings Relating To Which Was Pending Before The Assessing Officer On The Date Of Registration Of The Assessee U/S 12A Of The Act & The Objects & Activities Of Such Trust Or Institution Remained The Same For Such Preceding Assessment Year. In This Case, The Registration Was Granted To The Assessee On 22.01.2020 For Assessment Year 2020-21. However, On The Date Of Grant Of

Section 11Section 12ASection 2Section 250

Shri Rajkot Vishashrimali Jain Samaj, Rajkot vs. The ITO, Exemption Ward-1, Rajkot

In the result, appeal of the assessee is allowed

ITA 256/RJT/2022[2020-21]Status: DisposedITAT Rajkot13 Mar 2023AY 2020-21

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri G.R. Sanghavi, A.RFor Respondent: Shri B.D. Gupta, Sr. D.R
Section 11Section 119(2)(b)Section 12ASection 139Section 143Section 143(1)Section 250Section 288

M/S Alpha Educational Trust, Chennai vs. DCIT (Exemptions), Chennai

In the result, appeal of the assessee is partly allowed

ITA 588/CHNY/2022[2011-2012]Status: DisposedITAT Chennai10 Mar 2023AY 2011-2012

Bench: Shri Mahavir Singh, Vice-आयकरअपीलसं./I.T.A.No.588/Chny/2022 ("नधा"रणवष" / Assessment Year: 2011-12) M/S. Alpha Educational Trust Vs The Dcit (Exemptions), No.2/310, Jeeva Street, Chennai. Mondiamman Nagar, Red Hills, Chennai-600 052. Pan: Aacta 9230A (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Respondent: 08.03.2023
Section 11Section 12ASection 143(3)Section 147