2026 (4) TMI 1178

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....f the case are that assessee-society has filed an application before the Ld. CIT(E) in Form No. 10AB for registration u/s. 12A(1)(ac) of the Act on 25.09.2024. The Ld. CIT(E) with a view to verify the genuineness of activities of the assessee and compliance to requirements of any other law for the time being in force, a notice was issued through ITBA portal on 06.11.2024 requesting the assessee to upload certain information under the provisions of section 12AB(1)(b)(i) of the Act. In response to the notice, assessee submitted certain details and the Ld. CIT(E) noticed various discrepancies and issued another notice on 23.01.2025. Though, assessee responded to the notice but not furnished any written clarification and only submitted a brochu....

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....the year 2023-24 and for the same reason, assessee has not filed income tax return for AY 2024-25. He further submitted that on notices of activities, the assessee has held a conference at Goa in September 2024 attended by over 650 doctors from all over India. Brief note on activities given by the Secretary was attached to the mail and also invoices of conference expenses were attached from event manager. Thus, the activities were clearly indicated along with relevant photographs to effectively establish the functioning and attendance of the conference 4. Ld. Departmental Representation (DR) supported the order of Ld. CIT(E), but failed to pinpoint the specified violation with exactitude. 5. We have heard both the parties and perused ....

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....t Association (366 ITR 85) held that conducting management development programmes, public talks, and conferences amounts to educational activity. Similarly, in CIT (Exemption) v. Anesthesia Society (260 Taxman 375), the Rajasthan High Court held that organising medical seminars and research conferences constitutes charitable activity even if primarily attended by medical professionals. 18. Applying the same principle, we hold that the assessee's activities in organising neurology conferences and workshops squarely fall within the ambit of "education" under section 2(15). 19. The mere generation of surplus from an educational activity does not imply profit motive, so long as the surplus is applied solely towards the objects....