TMI Blog2015 (1) TMI 876X X X X Extracts X X X X X X X X Extracts X X X X ..... S JHAVERI AND MR. K.J.THAKER, JJ. MR PRANAV G DESAI, ADVOCATE FOR THE APPELLANT MR RK PATEL, ADVOCATE FOR THE RESPONDENT ORAL JUDGMENT (PER : HONOURABLE MR.JUSTICE K.J.THAKER) 1. This Appeal u/s.260A of the Incometax Act, 1961 is filed against the judgment and order dated 11.04.2014 passed by the Income Tax Appellate Tribunal, Rajkot in ITA No. 461/RJT/2013 whereby, the appeal filed by the assessee is allowed. 2. The facts in brief are that on 19.03.2013 the assessee filed an application for registration u/s.12A of the Act. For verification, the authority issued Notice to the assessee asking to produce necessary evidence in support of its application along with the books of accounts. On examination of the docu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nent to note that the assessee trust is giving sewing training class at Ramania, Taluka : Mundra, Kutch for women staying in rural areas to give them full training of preparing various clothes / garments so that they themselves can earn their own. The trust had provided raw materials like cloth, threads and other items free of charge to all the 80 mahils who had participated in the projects. By giving training in stitching and embroidery to rural women the sole purpose of the assesseetrust is to uplift them so that they can become independent. Though the assesseetrust is also charging meager fee, the Income and Expenditure Account shows the stitching training income of ₹ 1,92,668/whereas, expenses incurred for such activities amounts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /s.10(22) of the Act. In this case, the facts are different. Here, the assessee had applied for registration u/s.12A of the Act, which was not the case in the judgment relied upon by Mr. Desai. 7. This case essentially revolves around the scope and ambit of Section 12A of the Act where the assessee is engaged in the activity of imparting education to women staying in the rural areas. Hence, we are afraid to state that the said decision would not be of any help to the Revenue. 8. In our opinion, the judgment rendered by the Delhi High Court in the case of Institute of Chartered Accounts of India and Another v. Director General of Income Tax (Exemption) and Others, [2013] 358 ITR 91 (Delhi), which has been relied upon by the Appellate T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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