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2014 (5) TMI 736 - AT - Income TaxRejection of application for registration u/s 12A(a) of the Act - Objects of the Trust are mixed charitable and commercial – Held that:- The main and generic objects of the Trust are 'education', being a charitable activity for the general public utility - Income and Expenditure statement filed does not indicate the spending of the same for the objects narrated by the DIT (E) - it is a premature to deny the registration of the Trust u/s 12AA of the Act – Relying upon Sole Trustee, Lok Shikshana Trust [1975 (8) TMI 1 - SUPREME Court] - "Education" is a broad and generic term and the same should be understood in the context of the educational objects of the Trust – also in Samria Charitable Trust Versus DIT (E), Mumbai [2013 (6) TMI 330 - ITAT MUMBAI] it has been held that Education has different shades and all kinds of education are not covered by the provisions of section 2(15) of the Act - The education for the purpose of earning profits, imparting knowledge, which is required for getting employment are not covered by the provisions - the assessee is yet to commence its activities - there is neither institution nor any coaching classes conducted by the assessee as stated by the Managing Trustee at Bar - the matter should be re-visited by the DIT (E) for examining the basic facts – thus, the matter is remitted back to the DIT(E) – Decided in favour of Assessee.
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