2018 (4) TMI 197

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....ges only the following question of law, for our consideration: "Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in law in holding that the assessee is a charitable organization and is eligible for deduction under Section 11 of the Income Tax Act, 1961 ?" 3 The respondent- assessee is a Company registered under Section 26 of the Indian Companies Act, 1913 as a non-profit making Company. The principal objects of the respondent-assessee as per the Memorandum of Association is to inter-alia conduct educational activities in respect of the banking and kindred subjects by holding courses and also disbursing knowledge by lectures, discussions, books, correspondence with public bodies and individual....

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.... respondent-assessee's appeal. The impugned order of the Tribunal after examining the object clause as given in the Memorandum of Association gave a finding that the respondent-institute has been created for the purpose of development of banking personnel for/in the banking industry. The institute imparts education to the candidates who are connected with the banking industry. It has library facility, organizes lectures, seminars and undertake examinations for promoting bank officers. In the aforesaid context, the impugned order of the Tribunal concluded on facts which were before the Revenue Authorities that it exists for advancement of learning in the field of banking. Besides, on facts it found the fee structure of the institute for ....