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2018 (6) TMI 607 - AT - Income TaxDenial of registration u/s 12AA - object of Trust is for educational purposes - charitable nature of trust u/s 2(15) - whether assessee’s activity will fall within the last limb of “charitable purpose’’ which is advancement of general public utility? - Held that:- Imparting financial education to the general public through programmes sponsored by Goldman Sachs, ICICI, Tata, Reliance Life etc, will clearly show that pursuing such object would not come within the meaning of “education’’. In fact none of the objects as contained in the main object clauses of the MOA, will fall within the meaning of “education - assessee was not collecting any fees from any of the participants but admittedly, it was collecting substantial amount as sponsorship fees from various sponsors. Further, almost all of these sponsors were from private sector and not from any Department of Government. Since assessee’s activity was imparting financial skills, through programme sponsored by various companies and this in our opinion was nothing but rendering services in relation to trade, commerce or business carried on by such companies - also just because assessee was registered u/s 25 of the Companies Act, 1956 would not ipso facto make it eligible for registration u/s 12AA - thus unless the dominant activity show altruistic thought and action which reflects selflessness, we cannot say it involves any “charity’ - hence assessee is not carrying any charitable activity within the meaning of Section 2(15) - Decided against the assessee.
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