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Documents citing Tolani Education Society vs Deputy Director Of Income-Tax on 31 January, 2013

M/S. Rajasthan Cricket Association, ... vs Add.Cit. Range-2, Jaipur on 25 November, 2020

"24. ......Also in Tolani Education Society v. Deputy Director of Income Tax (Exemption) & Ors.,[2013] 351 ITR 184, the Bombay High Court has expressed a view inline with the Punjab and Haryana High Court view, following the judgments of this Court in the Surat Art Silk Manufacturers Association Case and Aditanar Educational Institution case as follows:
Income Tax Appellate Tribunal - Jaipur Cites 76 - Cited by 3 - Full Document

Dcit, C-1, (E), Chandigarh vs M/S Manav Mangal Society, Chandigarh on 27 May, 2021

Also Tolani Education Society v. Deputy Director of income Tax (Exemptions) & Ors. (2013) 351 ITR 184, the Bombay High Court has expressed a view in line with the Punjab & Haryana High Court view, following the judgements of this Court In the Surat Art Silk Manufacturers Association case and Aditanar Educational institution case as follows the fact that the Petitioner has a surplus of income over expenditure for the three years in question cannot by any stretch of logical reasoning lead to the conclusion thai the Petitioner does not exist solely for educational purposes or, as that Chief Commissioner held that the Petitioner exists for profit. The test to be applied is as to whether the predominant nature of the activity is educational. In the present case, the sole and dominant nature of the activity is education and the Petitioner exists solely for the purposes of imparting education. An Incidental surplus which is generated, and which has resulted in additions to the fixed assets is utilized as the balance-sheet would indicate towards upgrading the facilities of the college including for the purchase of library books and the improvement of infrastructure. With the advancement of technology, no college or institution can afford to remain stagnant. The Income-tax Act, 1961 does not condition the grant of an exemption under section 10(23C) on the requirement that a college must maintain the status-quo, as it were, in regard to its knowledge based infrastructure. Nor for that matter is an educational institution prohibited from upgrading its infrastructure on educational facilities save on the pain of losing the benefit of the exemption under section 10(23C). Imposing such a condition which is not contained in the statute would lead to a perversion of the basic purpose for which such exemptions have been taken granted to educational institutions. Knowledge in contemporary times is technology driven. Educational institutions have to modernize, upgrade and respond to the changing ethos of education. Education has to be responsive to a rapidly evolving Society. The provisions of section 10(23C) cannot be interpreted regressively to deny exemptions. So long as the institution exists solely for educational purposes and net for profit, the test is met.
Income Tax Appellate Tribunal - Chandigarh Cites 89 - Cited by 0 - Full Document

Income Tax Officer, Jaipur vs Rajasthan Cricket Association, Jaipur on 21 June, 2022

"24. ......Also in Tolani Education Society v. Deputy Director of Income Tax (Exemption) &Ors.,[2013] 351 ITR 184, the Bombay High Court has expressed a view inline with the Punjab and Haryana High Court view, following the judgments of this Court in the Surat Art Silk Manufacturers Association Case and Aditanar Educational Institution case as follows:
Income Tax Appellate Tribunal - Jaipur Cites 72 - Cited by 0 - Full Document

M/S. Yash Society vs Chief Commissioner Of Income-Tax And 2 ... on 12 March, 2015

In this context, it was held that section 10 (23C) cannot be ::: Downloaded on - 13/03/2015 00:01:34 ::: Rng 23 wp2565.10.doc interpreted regressively to deny exemption as educational institution exist for educational purpose and not for profit. There is no finding of the Court that the utilization of surplus was for acquisition of fixed assets. It was also not the case that the petitioner had not spent on educational activities but, for some other purpose outside the parameters of educational activity which was the sole object of the petitioner. However, in the present case, the petitioner has successively incurred a meagre expenditure on philanthropic activity namely expenditure towards treatment of weaker sections of the society and major amount was utilized for generation of assets. These facts therefore, completely differentiate the case of the petitioner from the facts of the case in Tolani Education Society (supra.) The intention of the legislature in making provisions of section 10 (23C) (via) is that an institution shall exist solely for philanthropic purpose and not for the purpose of profits. The expression "solely for philanthropic purpose" and "not for the purpose of profits" spells out a clear intention of the legislature that the institution should not merely exist for philanthropic purpose but existence shall not be for profits. Satisfaction of this twin test by an institution claiming a ::: Downloaded on - 13/03/2015 00:01:34 ::: Rng 24 wp2565.10.doc deduction would entitle it for the benefit of the provisions of section 10 (23C) (via) of the Act. In the petitioner's case, from the details of the accounts as submitted by the petitioner, this position remains hardly satisfied so as to enable the respondent no.1 to grant an approval for the purpose of the petitioner claiming exemption under the said provisions.
Bombay High Court Cites 22 - Cited by 0 - G S Kulkarni - Full Document

Vipan Langer, Educational Trust,, ... vs Department Of Income Tax on 1 January, 2016

130. Also in Tolani Education Society v. Deputy Director of Income Tax (Exemption) & Ors., (2013) 351 ITR 184, the Bombay High Court has expressed a view in line with the Punjab and Haryana High Court view, following the judgments of this Court in the Surat Art Silk Manufacturers Association Case and Aditanar Educational Institution case as follows:
Income Tax Appellate Tribunal - Amritsar Cites 39 - Cited by 0 - Full Document
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