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1 - 10 of 14 (0.31 seconds)Section 12AB in The Income Tax Act, 1961 [Entire Act]
Section 11 in The Income Tax Act, 1961 [Entire Act]
The Goa University Act, 1984
Section 12A in The Income Tax Act, 1961 [Entire Act]
Dahisar Sports Foudation, Mumbai vs Ito (E) (I), Mumbai on 9 November, 2017
26. As to whether the collection of fees for imparting
sports training would disqualify assessee for
registration and consequently eligibility for claiming
ITAT-Panaji Page 20 of 22
Yakshit Yuva Foundation Vs CIT(E)
ITA Nos.233 & 234/PAN/2025
exemption u/s 11 of the Act came for consideration
before the Ld. Co-ordinate bench in 'Dahisar Sports
Foundation Vs ITO(E)' [2017, 87 Taxmann.com 313 (Mum)],
wherein the assessee-trust's main object was
promotion of sports and games as advancement of
any other object of general public utility. There it held
that, collecting of certain charges from coaching
camps meant for promotion of sports and games only
could not alter its basic character of promotion of
sports/games being charitable purpose. Therefore,
the assessee held to be eligible for registration u/s
12A/12AB & consequential registration u/s 80G of
the Act and thus for claiming exemption u/s 11 of the
Act.
The General Clauses Act, 1897
Shyam Sundar Sarma vs Pannalal Jaiswal And Others on 4 November, 2004
In our thoughtful consideration, when an
application or appeal is barred by limitation and the
adjudicating or appellate authority who is in law
empowered to condone the delay, having noted such
fact of time barred application/appeal, deals
therewith in the order and then if proceeds on merits
of the matter then it is good enough to sweepingly
infer that, said adjudication on merits in law
succeeded only upon due admission of belated
application or appeal, thus by deemingly condoning
the delay in filing of such application or instituting of
such appeal as the case may be. We found this
proposition fortified in the case of 'Shyam Sunder
Sarma Vs Pannalal Jaiswal [2005, 1 SCC 436(SC)]
which in turn followed the larger bench decision
rendered in 'Sheodan Singh Vs Daryao Kunwar' [AIR
1966, SC 1332] by the Hon'ble Apex Court.
Sheodan Singh vs Smt. Daryao Kunwar on 14 January, 1966
In our thoughtful consideration, when an
application or appeal is barred by limitation and the
adjudicating or appellate authority who is in law
empowered to condone the delay, having noted such
fact of time barred application/appeal, deals
therewith in the order and then if proceeds on merits
of the matter then it is good enough to sweepingly
infer that, said adjudication on merits in law
succeeded only upon due admission of belated
application or appeal, thus by deemingly condoning
the delay in filing of such application or instituting of
such appeal as the case may be. We found this
proposition fortified in the case of 'Shyam Sunder
Sarma Vs Pannalal Jaiswal [2005, 1 SCC 436(SC)]
which in turn followed the larger bench decision
rendered in 'Sheodan Singh Vs Daryao Kunwar' [AIR
1966, SC 1332] by the Hon'ble Apex Court.
Sole Trustee Loka Shikshana Turst vs Commissioner Of Income Tax, Mysore on 28 August, 1975
In view of interpretation laid in 'Loka
Shikshana Trust' (supra) & 'ACIT Vs AUDA' [2022, 115
CCH 253] and the definition of schooling adopted on
the strength of judicial support laid in 'CoC Vs M/s
Welkin Foods' (supra), it is ostensibly clear that an
activity of providing scholastic sports training and
conducting incidental workshops was with a focal
view to develop sports knowledge, skill, mind &
character of school students, which does fall in the
realm of 'education' as used in section 2(15) of the Act.