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Issues involved: The issue involves whether the activities conducted by the Institute of Chartered Accountants of India (ICAI) fall within the purview of "Education" under section 2(15) of the IT Act, specifically regarding income from coaching classes and the applicability of exemptions u/s 11 and u/s 12A.
Summary: The Assessing Officer had held that the income from coaching classes was taxable as the assessee was not registered u/s 12A and had not produced evidence of registration. Consequently, the benefit of section 11 of the IT Act was denied, and the income was assessed at a specific amount after disallowing the exemption u/s 11 on the grounds that coaching income was considered a business activity and that proper books of accounts were not maintained. Upon appeal, the Ld. Commissioner of Income Tax (Appeals) referred to previous appellate orders and emphasized that the income from coaching classes was not a business activity but an ancillary activity aligned with the main objectives of the Institute. The Ld. Commissioner noted that the income was exempt u/s 10(23C)(iv) and u/s 11 as it fell within the definition of charitable purpose under section 2(15) of the Act. The Tribunal upheld the decision of the Ld. Commissioner of Income Tax (Appeals) based on the precedent set in previous tribunal orders, where it was established that the income from coaching classes was educational in nature and exempt under sections 10(23C)(iv) and 11 of the IT Act. The Revenue's appeal was dismissed, affirming the order of the Ld. Commissioner of Income Tax (Appeals). In conclusion, the Tribunal found no infirmity in the Ld. Commissioner's order and upheld the decision, resulting in the dismissal of the Revenue's appeal.
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