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2022 (10) TMI 397
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....JP//2022 09.05.2022 22.11.2016 u/s143(3) 2017-18 270/JP//2022 09.05.2022 10.12.2019 u/s143(3) 2018-19 271/JP//2022 10.05.2022 07.04.2021 u/s143(3) r.w.s. 143(3A) & 143(3B) 2016-17 275/JP//2022 22.04.2022 06.12.2018 u/s143(3) 2. At the outset of hearing, the Bench observed that there is delay of 21 days in filing the appeal by the Revenue for which the ld. DR of the Department filed an application for condonation of delay with following prayers. "2. The appeal in the above case was filed late by 21 days. The reason for delay in filing of appeal are explained as under:- a. The appeal order in this case was received from the office of CIT on 24.05.2022. As per the direction of the Ld. CIT(A), an opportunity to file certain details was provided to the assessee vide DIN & Letter No. ITBA/COM/F/17/2022-23/1043224369(1) dated 27.05.2022. The time allowed to the assessee was seven days. In the meantime, undersigned went on earned leave from 06.06.2022 to 19.06.2022 and joined back on 20.06.2022. On return from leave, the Central Scrutiny Report was immediately forwarded to the higher offices. b. As there is....
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....es not stipulate any such condition." 5. Brief facts of the case are that the return of income declaring total income of Rs. Nil was e-filed on 08.10.2016. The case was selected for complete scrutiny through CASS and e-notice u/s. 143(2) of the IT Act, 1961 was issued on 08.07.2017 which was duly served upon the assessee in time. The assessee is registered under section 12AA of the Act. The objection of the assessee corporation is to provide road transportation in the State of Rajasthan and in other states as well. During the year its total revenue receipts were Rs. 17,07,56,24,135/-. After claiming various expenditure of Rs. 21,99,97,55,976/- and adjustment of disallowable expenditure it has shown net loss of Rs. 4,92,41,31,841/-. The corporation is registered as a charitable institution u/s. 12A(a) of the IT Act dated 08.03.1989. The objects fall in the last limb of the definition of section 2(15) i.e. advancement of any other object of general public utility. 6. Aggrieved by the order of the AO, the assessee preferred in appeal before the NFAC who has deleted the addition made by the AO. 7. The AO assessed the finding that the objects of the corporation are definitely c....
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....ubmission, stated that- "In compliance with above matter relating to carry forward of deficit, assessee Corporation submits that in case of non- profit organization which are registered under section 12A of Income Tax Act, 1961 deficit would be brought forward & eligible for application. The proposition is based on jurisdictional High Court Ruling in case of Maharana of Mewar Charitable Foundation reported in 164 ITR 0439 (Raj). The deficit is eligible for carry forward and may please be allowed. Please further note assessee Corporation submits that it is recognized u/s. 12A of Income Tax Act and the ruling of jurisdictional High Court is valid and binding. The other citation on above issue also favour assessee namely CIT Vs. Maharana of Mewar Charitable Foundation 164 ITR 271 ITR 293 (Guj) CIT Vs. Shri Plot Swetambar Murti Pujak CIT Vs. Matriseva Trust 242 ITR 20 (Mad) Govindu Naidker Estate Vs. ADI 248 ITR 368 (Mad) This carry forward of deficit is statutory requirement and cannot be denied. It is humbly prayed that the deficit claimed to be carried forward for set off in the next years may be allowed as claimed." 9. Howeve....
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.... except to provide transport service to the people as the details of assessee's profit statement shows that it has incurred consistent losses by charging reasonable fare and also by providing services to far-flung rural areas where running of transport services may not be commercially viable. Thus even though running the transport services are of the nature of commerce or business, the primary object of the corporation itself cannot be treated as running a business activity and the dominant object of the corporation comes under the purview of advancement of general public utility and not under the purview of business since motive of earning profit is missing in the object of corporation. The activities of corporation are held to be covered under the charitable purpose and assessee is not caught by the newly inserted proviso in sec 2(15) in view of the decision of honourable Delhi High Court (supra) reading down the said proviso and holding to look into the dominant object to see whether activity is to the profit or it is for providing advancement of object of general public utility. Further, the theory of the pre-dominant object was also upheld by the Rajasthan High Co....
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....s of corporation are not come under the purview of business. Activities and object of corporation is to provide low cost, efficient services to transportation for passengers. Amount charged as fare is with a view to survive and not for profit making. Further, A.Y. 2010-11 and A.Y. 2011-12 has already been considered by this co-ordinate bench of ITAT. After hearing long arguments, evidences and established law honorable ITAT remanded back the case in the file of Ld. CIT(A) to consider all the material and decide the issue of registration u/s. 12AA. Both the years, the appeal was allowed by Ld. CIT(A) for which copies were filed during earlier hearing. It is very much relevant to consider finding of honorable ITAT, which is placed in para 21 of ITAT order which, I want to read if allow me that The next question that arise for consideration is whether the activities of the assessee corporation involves carrying on of activities in the nature of trade, commerce or business or any activity of rendering of services in relation to any trade, commerce or business for a cess, fee or any other consideration and the proviso to section 2(15) is applicable in the instant case. As per t....
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....erty at raise its aforesaid ITA Nos. 885 & 886/JP/2018 Rajasthan State Road Transport Corporation, Jaipur Vs. DCIT, Jaipur 18 contentions before the ld. CIT(A). In the result, the matter is set-aside to the file of the ld. CIT(A) after providing reasonable opportunity to the assessee corporation. Since the A.Y. 2010-11 and A.Y. 2011-12 were remanded back after hearing and considering all the documents, evidences, arguments by ITAT and Ld. CIT(A) has allowed the same for which no appeal has been filed further, the case has been settled in favour of Corporation. My Ld. Brother has said in earlier hearing that the appeal for A.Y. 2010-11 and A.Y. 2011-12 were not filed considering the tax effect is altogether wrong. Since it the question of law the CBST circular for restriction of appeals is not applicable. Further, if the argument of my LD. Brother is right than all the appeals for these 5 years should not have been filed, since the issue does not carry ant tax effect as per arguments of ld. DR. On the facts, your honour assessee corporation is state government owned organization providing transportation facilities to passengers by running of vehicles in th....
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....nsideration by declaring loss of Rs. 80 crore +. It's accumulated losses are now more than Rs. 2000 crores. I have also attached herewith the yearly chart for losses page no 5 of paper book. from this data it is clear that corporation is not running with the objective of profit making actually corporation loss is basically a relief to majority people of Rajasthan and also the other states by providing services in very low or free fare and this loss is increasing day by day 5. State Government principally decides the routes facilities, fare, concessions, amenities and all such decides after taking care interest specially to poor people, widows, ST, SC etc. Assessee corporation cannot increase or decrease the rates on its own order for fixing the price by state government is placed on page no 6 of paper book. 6. Assessee corporation is charging much low fare in comparison to the private tour operators, your honours I would like to briefly differentiate the fare charged by private tour operators and RSRTC may I allow to do, Private tour operators charge Rs. 300/- for the same route while RSRTC charge 228/- please refer page no 7-8 of paper book where I have place....
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....#39;ble high court stated in appeal filed by revenue in case of CIT Jodhpur vs. Jodhpur Development Authority and CIT Bikaner vs. Urban Improvement Trust Bikaner held that when the object of institution to provide facility which involves the advancement of any other object for general public utility and for that purpose the settled position of law emerged that if the primary or predominant object of an institution is charitable any other object which might not charitable but which is ancillary or incidental to the dominant purpose may be involving element of profit would not prevent the institution from being a valid charitable trust coy of judgment is placed on (page no 18-51 of paper book) Alternatively your honours The predominant object for which the corporation has been established by the state is to provide efficient transport services to the people in public interest and even after sufferance of losses. As per section 3 of the Rajasthan State Road Transport Corporations Act, 1950 (page n 52-66) (a) the advantages offered to the public, trade and industry by the development of road transport; (b) the desirability of coordinating any form of....
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....ecision of ITAT Bangalore in case of M/s. Karnataka State Road Transport Corporation vs. ACIT (Exemption) "Keeping in mind the above factual aspects and the provisions of the RTC, Act, 1950 and principle laid down in the aforesaid decision of the Hon'ble Delhi High Court in the case of India Promotion Organization (supra), in our view, will clearly show that the Assessee does not driven primarily by desire or motive to earn profits but to do charity through advancement of an object of general public utility. The proviso to Sec. 2(15) of the Act is therefore not applicable to the case of the Assessee. We therefore concur with the view of the CIT(A) and hold that the Assessee is entitled to the benefits of Sec. 11 of the Act. The AO has not disputed the conditions necessary for allowing exemption u/s. 11 of the Act, except the applicability of proviso to Sec. 2(15) of the Act. In view of our conclusions that the said proviso is not applicable to the case of the Assessee, we hold that the Assessee's income is entitled to the benefits of Sec. 11 of the Act. 15. With regard to the arguments of the learned DR, we are of the view that the same are without any merit. The p....
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....ot allowable for the assessee corporation. The assessee corporation activity are in the commercial in nature that the activity being carried which are not charitable and the objects of the Corporation are definitely charitable as their " general public utility" and there may be profit motive. The ld. DR further submitted that in view of the amended provisions of Section 2(15) of the Act which defines the charitable purposes that if the receipts from the activities which are commercial in nature were exceeding of Rs. 25 lacs. The advancement of the general public utility will be called charitable. Further, he explained that the basic principles for exemption of the income are mutual association is that there is a common identity of contributors and participants. During the assessment proceedings the AO has considered the reply filed and is not found acceptable, the relevant paras 5 to 9 has been considered by the ld. DR that the assessee corporation does not come within the definition of section 2(15) of the Act which defines charitable purpose it comes under business income. 13. The ld. AR for the assessee submitted that it is squarely covered matter where this Bench has passed ....
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....poration Act 1950 and has argued that the object was to provide efficient transport services to the public and not to earn profits. We find that the provision of Rajasthan State Road Transportation Corporation Act 1950 need to be examined in detail to determine the dominant intent and purpose of setting up of the assessee corporation and in the absence of findings of the lower authorities, we are constrained to remand the matter back to the file of the ld. CIT(A) to examine the same afresh taking into consideration the decisions of the Hon'ble Delhi and Rajasthan High Court referred supra. The assessee corporation is at liberty at raise its aforesaid contentions before the ld. CIT(A). In the result, the matter is set-aside to the file of the ld. CIT(A) after providing reasonable opportunity to the assessee corporation. 22. In ITA No. 886/JP/2018, since facts and circumstances of the case are exactly identical to facts and circumstances of the case in ITA No. 885/JP/2018, our findings and directions contained therein shall apply mutatis mutandis to this appeal." 14. It was further submitted that thereafter the NFAC has passed the order in favour of the assessee. Furt....
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.... three limbs of section 2(15), i.e., relief of the poor, education or medical relief. Consequently, where the purpose of a trust or institution is relief of the poor, education or medical relief, it will constitute 'charitable purpose' even if it incidentally involves the carrying on of commercial activities. 2.2. 'Relief of the poor' encompasses a wide range of objects for the welfare of the economically and socially disadvantaged or needy. It will, therefore, include within its ambit purposes such as relief to destitute, orphans or the handicapped, disadvantaged women or children, small and marginal farmers, indigent artisans or senior citizens in need of aid. Entities who have these objects will continue to be eligible for exemption even if they incidentally carry on a commercial activity, subject, however, to the conditions stipulated under section 11(4A) or the seventh proviso to section 10(23C) which are that (i) the business should be incidental to the attainment of the objectives of the entity, and (ii) separate books of account should be maintained in respect of such business. Similarly, entities whose object is 'educ....
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....ntitled to claim that its object is charitable purpose. In such a case, the object of 'general public utility' will be only a mask or a device to hide the true purpose which is trade, commerce or business or the rendering of any service in relation to trade, commerce or business. Each case would, therefore, be decided on its own facts and no generalization is possible. Assessees, who claim that their object is 'charitable purpose' within the meaning of Section 2(15), would be well advised to eschew any activity which is in the nature of trade, commerce or business or the rendering of any service in relation to any trade, commerce or business." The ld. AR for the assessee has further explained the purpose of nature and the activities of the Corporation is deemed to be under the advancement of any other object of general public utility than still the activities of the Corporation does not qualify the test of running trade, commerce or business activity for the fee. We are of the opinion that the assessee Corporation is continue to be within the definition of charitable u/s. 2(15) of the Act in relief to poor as main limb and first limb. Relief to poor encompasses a....
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....2007-8 to 2016-17 the losses incurred by the assessee corporation is more than 2000 crores considering the losses incurred by the RSRTC we come to the conclusion that there is not profit motive and the income is not from the business income the activities in purely in charitable in nature. Taking into consideration the fixing of the price also is done by the State Government. The assessee corporation does not have any roll in fixing the price. The ld. AR submitted that the documents where the State Government is fixing the price for the Corporation which is reproduced as under:- 15. The ld. AR further pointed out the differences where the private tour operator charges high fares comparing to the corporation for the same route. For an example the ld. AR for the assessee has produced documentary proof ticket at paper books 7 and 8 which is reproduced as under:- The ld. AR for the assessee further submitted that Section 3 of the Act explains that established of Road Transport Corporation where the facilities is in charitable in nature. The establishment of Road Transport Corporations in the States. The State Government having regard to the advantages offered to the public, trade....
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....for the A.Y. 2009-10 dated 14.10.2021 that the assessee has raised several grounds and an additional ground. However, during the course of hearing, the ld. AR for the assessee limited his submission only to the following two issues, namely-whether the CIT(A) is justified in law in holding that the assessee is hit by proviso to section 2(15) of the Act and consequently confirming the excess of income over expenditure of Rs. 47,70,52,000/-, as taxable income of the assessee. Keeping in mind the above factual aspects and the provisions of the RTC, Act, 1950 and principle laid down in the aforesaid decision of the Hon'ble Delhi High Court in the case of India Promotion Organization (supra), in our view, will clearly show that the assessee does not driven primarily by desire or motive to earn profits but to do charity through advancement of an object of general public utility. The proviso to Sec. 2(15) of the Act is therefore not applicable to the case of the assessee. We therefore concur with the view of the CIT(A) and hold that the Assessee is entitled to the benefits of Sec. 11 of the Act. The AO has not disputed the conditions necessary for allowing exemption u/s. 11 of the Act,....
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....¨à¥à¤¤à¥à¤°à¤¤à¤¾ सैनानी का à¤à¤• सहयोगी * निशà¥à¤²à¥à¤• दिनांक 07.05.1994 4. सà¥à¤µà¤¤à¤¨à¥à¤¤à¥à¤°à¤¤à¤¾ सैनानियों की विधवाà¤à¤‚ * निःशà¥à¤²à¥à¤• दिनांक 04.05.1989 5. सà¥à¤µà¤¤à¤¨à¥à¤¤à¥à¤°à¤¤à¤¾ सैनानी की विधवा का à¤à¤• सहयोगी * निःशà¥à¤²à¥à¤• दिनांक 02.03.2007 * सà¥à¤µà¤¤à¤¨à¥à¤¤à¥à¤°à¤¤à¤¾ सैनानी à¤à¤µà¤‚ सà¥à¤µà¤¤à¤¨à¥à¤¤à¥à¤°à¤¤à¤¾ सैनानियों की विधवाओं ....
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....दिवासी कà¥à¤·à¥‡à¤¤à¥à¤° की आदिवासी बालिकाये ककà¥à¤·à¤¾ निःशà¥à¤²à¥à¤• माह - जून, 1994 8 तक अधà¥à¤¯à¤¯à¤¨ हेतॠसà¥à¤•à¥‚ल जाने व आने के लिये 8. पदम पà¥à¤°à¤¸à¥à¤•à¤¾à¤° से समà¥à¤®à¤¾à¤¨à¤¿à¤¤ वà¥à¤¯à¤•à¥à¤¤à¤¿ निःशà¥à¤²à¥à¤• दिनांक 24.05.2010 9. पदम पà¥à¤°à¤¸à¥à¤•à¤¾à¤° से समà¥à¤®à¤¾à¤¨à¤¿à¤¤ वà¥à¤¯à¤•à¥à¤¤à¤¿ का à¤à¤• सहयोगी निशà¥à¤²à¥à¤• दिनांक 06.04.2011 10. à¤....
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.... में दिनांक 31.08.1998 50% छूट निःशà¥à¤²à¥à¤• दिनांक 03.08.2010 16. कम दृषà¥à¤Ÿà¤¿ निःशकà¥à¤¤à¤¤à¤¾ निःशà¥à¤²à¥à¤• दिनांक 03.08.2010 17. मानसिक रà¥à¤—à¥à¤£à¤¤à¤¾ निःशà¥à¤²à¥à¤• दिनांक 03.08.2010 18. मानसिक रà¥à¤—à¥à¤£à¤¤à¤¾ से गà¥à¤°à¤¸à¤¿à¤¤ वà¥à¤¯à¤•à¥à¤¤à¤¿ का à¤à¤• सहयोगी निःशà¥à¤²à¥à¤• दिनांक 03.08.2010 19. कà¥à¤·à¥à¤Ÿ रोगमà¥à¤•à¥à¤¤ निःशà¥à¤²à¥à¤• दिनांक 03.08.2010 20.4 ....
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....क 21.6.2013 30% छूट दिनांक 28.04.2014 * यातà¥à¤°à¥€ किराया में 30% छूट दिनांक 04.10.2013 केवल राजसà¥à¤¥à¤¾à¤¨ राजà¥à¤¯ सीमा तक यातà¥à¤°à¥€ किराया में 30% छà¥à¤Ÿ * दिनांक 07.03.2014 * 37 हीमोफिलिया (Hemophilia ) रोगी यातà¥à¤°à¥€ किराया में दिनांक 15.10.2014 75% छूट 38. हीमोफिलिया (Hemnophilia) रोगी का à¤à¤• सहयोगी यातà¥à¤°à¥€ किराया में द....
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....• (जनसमà¥à¤ªà¤°à¥à¤• ) / संचालन / ( ) रा.प.नि. मà¥à¤–à¥à¤¯à¤¾à¤²à¤¯ जयपà¥à¤° 12. सहा. लेखाधिकारी (टिकिट / अंकेकà¥à¤·à¤£) राजसà¥à¤¥à¤¾à¤¨ परिवहन निगम, मà¥à¤–à¥à¤¯à¤¾à¤²à¤¯ जयपà¥à¤° 13. समसà¥à¤¤ मà¥à¤–à¥à¤¯ पà¥à¤°à¤¬à¤¨à¥à¤§à¤• / पà¥à¤°à¤¬à¤¨à¥à¤§à¤• (वितà¥à¤¤ / यातायात) राज. परि. निगम आगार 14. कनà¥à¤Ÿà¥à¤°à¥‹à¤² रूम मà¥à¤–à¥à¤¯à¤¾à¤²à¤¯ जयपà¥à¤° को à¤à¥‡à¤œà¤•à¤° लेख है कà....