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2014 (9) TMI 513 - AT - Income TaxNature of activity – Scope of education u/s 2(15) – exemption u/s 11 & 12 - Services provided to government agencies to educate people in the areas of Urban Housing Development for poor and for their upliftment – Held that:- CIT(A) has rightly observed that the activities of the assessee are identical and it was found that assessee was involved in helping various Government Agencies or foreign Government Agencies under SARC in providing training to the persons in the field of housing for poor sections of the society and advising the Government for their upliftment and no work is undertaken for any profit motive - CIT(A) has observed that various assignments undertaken have been mentioned which clearly reveal the fact that appellant's activities are in the nature of education as it is providing the training to various persons of the Indian Government and overseas Governments and these training programs are in the nature of education and education programs have been organized by the Institute are mainly for the Government of India which are not of a commercial nature - The issue of charging the fees and number of students to participate in the course are decided by Government of India - the assessee has submitted some additional facts to substantiate its claim regarding the Trust is a charitable institution. The society is not engaged in any trade, commerce or business – it simply providing the services to various Government Agencies both Indian & Overseas to hold seminars, to educate people in the areas of Urban Hosing Development for poor and for their upliftment - There is no element of profit involved in our activity and the entire amount received is spent either for meeting expenditure or the balance / surplus kept in the Bank as per the norms for future utilizations - CIT(A) has rightly held that the assessee’s activities fall under the 2nd limb of the Section 2(15) - as the activities of the assessee has been found to be in the nature of education within the meaning of Section 2(15), benefit of section 11 and 12 given by the CIT(A) is upheld – Decided against revenue.
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