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2018 (12) TMI 604

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..... hetists, it cannot be said that the object of the society is confined to its members practicing in Sriganganagar and Hanumangarh Districts. Obviously, the education programme and research work to be undertaken by the assessee society in larger perspective are going to benefit the public at large and therefore, the activities of the assessee society do fall within purview of general public utility so as to make it entitled for registration under Section 12A of the Act. We are firmly of the view that the issue involved in the present appeal stands squarely covered by decision of the Apex Court in Ahmedabad Rana Caste Association’s case [1971 (9) TMI 8 - SUPREME COURT] and decision of this court in Jodhpur Chartered Accountants Society’s .....

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..... society might be catering to only one particular branch of doctors, but it is not the case of the department that the benefit will be accruing to specified individuals rather, all the doctors practising Anaesthesia within the district of Sriganganagar and Hanumangarh will stand benefited by the activities of the society. Relying upon a decision of the Hon ble Supreme Court in the matter of Ahmedabad Rana Caste Association vs. CIT , (1971) 82 ITR 704 and a Bench decision of this court in CIT vs. Jodhpur Chartered Accountants Society , 258 ITR 548 (Raj.), the ITAT held that the assessee society is eligible for the benefit of registration under Section 12A of the Act. 4. In Ahmedabad Rana Caste Association s case (supra), the Suprem .....

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..... ls but by virtue of their membership of a specified class, the common quality uniting potential beneficiaries into the class being essentially an impersonal one. (Emphasis supplied) 5. In Jodhpur Chartered Accountants Society s case (supra), a Bench of this court while dealing with the question as to whether the assessee association constituted to educate the members of the profession on the subject of auditing, accounting, direct or indirect taxes by holding seminars, conferences and workshops etc. falls within the purview of Section 2(15) of the Act so as to make it entitle to registration under Section 12A of the Act, relying upon inter alia the decision of Supreme Court in Ahmedabad Rana Caste Association s case (supra), observ .....

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..... and practical work and to organise the seminars etc. Thus, in the considered opinion of this court, merely because the society is primarily created for the benefit and convenience of Anesthetists, it cannot be said that the object of the society is confined to its members practising in Sriganganagar and Hanumangarh Districts. Obviously, the education programme and research work to be undertaken by the assessee society in larger perspective are going to benefit the public at large and therefore, the activities of the assessee society do fall within purview of general public utility so as to make it entitled for registration under Section 12A of the Act. 7. For the aforementioned reasons, we are firmly of the view that the issue involv .....

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