DCIT v. JMJ Education Society (2021) 190 ITD 496 (Bang.)(Trib.)

S. 11 : Property held for charitable purposes-Education-Survey-Capitalisation on fee-Surplus was incidental to educational activates-Denial of exemption was held to be not justified. [S. 2(15), 12AA, 133A]

Held that the surplus earned by assessee was incidental while carrying out main objects of trust and same was ploughed back for educational purposes only. Commission payment was for liasoning to make public aware about education courses offered by assessee which was very much essential in these days especially considering number of educational institutions available. Denial of exemption was held to be not justified. (AY. 2010-11, 2011-12)