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Issues involved: Appeal against refusal to renew approval u/s 80G of Income-tax Act, 1961.
Summary: The appeal was filed by the assessee against the order of DIT (Exemptions), Chennai, denying renewal of approval under Section 80G of the Income-tax Act, 1961. The DIT (Exemptions) refused renewal based on the opinion that the assessee's activities, including conducting courses, seminars, and publishing professional books, were commercial in nature. The DIT (Exemptions) cited an amendment to Section 2(15) of the Act as the reason for denying approval. The assessee contended that its activities were educational in nature, as it was a study circle of Chartered Accountants aimed at improving knowledge. The assessee argued that the book publishing was part of its educational activities and not for commercial purposes. The DIT (Exemptions) argued that the assessee's activities only benefited Chartered Accountants and not the general public, thus not falling under charitable activities as per Section 2(15) of the Act. After considering the submissions, the tribunal found that the assessee, being a Chartered Accountants Study Circle, was engaged in educational activities that benefited both professionals and the general public. The tribunal held that the activities were not commercial but educational, aimed at improving the skills of Chartered Accountants for the benefit of society. The tribunal concluded that the assessee was entitled to approval under Section 80G of the Act, and directed the DIT (Exemptions) to grant renewal of approval. Therefore, the appeal of the assessee was allowed, and the order of the DIT (Exemptions) was quashed, with directions to renew the approval under Section 80G of the Act as requested by the assessee.
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