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2016 (10) TMI 177 - AT - Income TaxDenial of exemption u/s 11 - whether the assessee is engaged in the business of activities not covered within the meaning charitable as defined in section 2(15) and that the activity of training of cadets was not qualified to be education and also that the assessee has been making profit on continuous basis and without any charitable object as provided under section 2(15)? - Held that:- All the courses may not be approved by the Director General of Shipping but that by itself is no ground to hold that the purpose is not charitable. The assessee trust was set up to administer and maintain technical training institution at various places in India for pre-sea and post-sea training for the ships and maritime industry and was engaged to provide on-board and offshore training and also seems to be education and accordingly, held that there is no substantial question of law and dismissed the appeal of the revenue. We find that the case of assessee is squarely covered by the ratio laid down by the jurisdictional High Court in the case of Samudra Institute of Maritime Studies Trust, (2014 (9) TMI 575 - BOMBAY HIGH COURT ). Respectfully following the above mentioned judgment of Hon’ble High Court we set aside the order of the ld.CIT(A) and direct the AO to allow the benefit an enumerated under section 11 of the Act by deleting the addition. - Decided in favour of assessee
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