2025 (3) TMI 2242

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...., CA, Shri Deepesh Garg, Adv For the Revenue : Shri Surender Pal, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No.4860/Del/2024 for AY 2022-23, arises out of the order of the Commissioner of Income Tax (Exemptions), Chandigarh [hereinafter referred to as 'ld. CIT(E)', in short] in Appeal No. ITBA/EXM/F/EXM45/2024-25/1067833675(1) dated 21.08.2024. 2. Though the assess....

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....eking permanent registration of the trust. This application was sought to be rejected by the learned CIT(Exemptions) on the ground that assessee's activity, though charitable in nature, falls under the ambit of advancement of general public utility (namely the seventh limb of the definition of charitable purpose as per section 2(15) of the Act). The learned CIT (exemptions) observed that assessee ....

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.... abundantly clear that assessee is primarily engaged in the first and second limb of charitable purpose as defined in section 2(15) of the Act. Hence, the activities carried out by the assessee cannot be construed to be falling within the ambit of advancement of general public utility so as to make the proviso to section 2(15) of the Act applicable. Hence, we have no hesitation to hold that the Le....