S.11: Property held
for charitable purposes - Education-Conducting seminars, workshops and
diploma courses are
educational activities. [S.2(15)]
Assessee an educational institution
conducting various courses categorized as continuing education
diploma and certificate programmes,
management development programmes, seminars and workshops and conferences. 80 %
receipts were from continuing education programme. The A.O. was of the opinion that
on going through the nature of courses and duration, the resultant surplus for
each activity, the activity of the assessee is not educational and it was held
by the A.O. that the assessee's activities are not educational and since the
provisions of Section 2(15) are applicable and therefore the assessee is not entitled
for exemption. In appeal CIT (A) also confirmed the view of A.O. On appeal the
Tribunal held that the assessee is conducting various diploma courses,
certificate progarmmes seminars, workshops etc all these programmes fulfilled
systematic instruction and training test hence covered under section 2 (15) as
education hence eligible for exemption under section 11. (A.Y.2009-10)
Ahmedabad Management
Association v. JDIT(Exemption) (2013) 143 ITD 476 (Ahd.)(Trib.)
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