Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2023 (9) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (9) TMI 897 - GUJARAT HIGH COURTGrant registration / certificate to the assessee trust u/s 10(23C)(vi) [Erroneously mentioned as “u/s. 10(23C)(vii)] - CIT(E) found that it cannot be said that the trust was predominantly engaged in carrying educational activities - tribunal granted registration - HELD THAT:- As on reproduction of the trust deed, it found that the trust carried out all activities so as to spread and impart education among people and to comment and develop institutions, hostels, kindergarten, aanganwadi etc. As far as the other purposes of the trust in running other activities is concerned, it was found that though it was the sole object of the institution to provide education, the ancillary activities such as promotion of cultural and social activities were co-related to the main activity of education. Perusal of the order of the Tribunal would indicate that the Tribunal found that the fees received from the students and transportation etc. were for reimbursing expenses for such purposes. The Profit and Loss account of the trust also clearly established that the trust is engaged in the educational activities and the nominal profit that it earned was not a ground on which the CIT(E) would have disregarded the application. Having perused the order of the Tribunal, we find no reason to interfere. No substantial question of law is involved.
|