AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2020 (4) TMI 683
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....esponse to the queries raised the counsel of the applicant company submitted the reply stating that Sanjhi Sikhiya Foundation is a charitable educational Entity working towards improvement of the educational paraphernalia of the Government Schools. The applicant has claimed that the activities qualify under the "Education" limb. The contention of the applicant is not amenable as such activities are not covered under section 2(15) of the Income Tax Act. For the purposes of claims of education the definition propounded by the Apex Court is the guiding factor. This contention of the applicant is not acceptable as mere gaining of knowledge or skill does not qualify for the label education in the sense of the term explained by the Apex Court in ....
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....essee is in appeal before us. 3. The Ld. AR argued in support of its case and submitted that order under challenge in unsustainable because the same is based on conjectures and surmises. 4. On the other hand, the Ld. CIT-DR relied on the impugned order and submitted that the same is well reasoned order and therefore does not require any interference by this Court. 5. Having heard the parties and perused the material available on record. The Ld. CIT(E) has held that the contention of the assessee is not amenable as such activities are not covered u/s 2(15) of the Income Tax Act. Further the contention of the assessee is not acceptable as mere gaining of knowledge of skill does not qualify for the label education in the sense of the term e....
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....stated aims and objects of the company (assessee) are as under: To provide professional development of young people to enable them to lead change initiatives and solve local problems in all types of education but not limited to primary education, adult education, continuing education, health related education, education/athletics /sports, vocational and technical educational, all education that is critical to the economic, intellectual, physical, spiritual development of an individual, family, community and the nation by initiating, undertaking and supporting relevant projects and programs." As per amendment in section 2(15) of the Act, Yoga has also been included as a part of education which is also one of the object of the assessee in ....
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....efore the CIT(E), however, considering the principles laid down by the various Courts as it is not in controversy that till the adjudication of application u/s 12AA of the Act, the trust was at nascent stage and all the activities which are reflecting from the documents submitted herein are of the later stage, however, in our considered opinion at the time of disposal of application, the Ld. CIT(E) in order to satisfy himself about the genuineness of the activities of the trust or institution can call for such documents or information from the trust or institution as he thinks necessary and also empowered to make such enquiry as he may deem fit necessary in this behalf , secondly that after satisfying himself about the object of the trust o....
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.... sold and proceeds thereof credited to the Rehabilitation and Insolvency Fund formed under section 269 of the Act. 11. The Company can be amalgamated only with another company registered under section 8 of the Act and having similar objects." From clause 10 of the aforesaid provisions, it reflects that in case of winding up or dissolution of the company, the property of the company shall be given or transferred to such other company having objects similar to the objects of this company, subject to such conditions as the Tribunal may impose, or may be sold and proceeds thereof credited to the Rehabilitation and Insolvency Fund formed u/s 269 of the Act. Further clause 11 prescribes that the Company can be amalgamated only with another com....