| |
| The Tax Publishers2019 TaxPub(DT) 4613 (Asr-Trib) INCOME TAX ACT, 1961
Section 12AA
Running a playschool, did not fit into the concept of education even more despite claim of upgradation (up to Fifth Standard) with efective from 1-4-2017, no evidence with regard thereto had been furnished. Accordingly, denial of regsitration under section 12AA was justified.
|
Charitable trust - Registration under section 12AA - Allowability - Assessee-engaged in running a play school
Assessee, registered under Societies Registration Act, 1860, was running a school under the name and style of 'Mother's Pride School' run on a franchise basis, entering into a franchise agreement with M/s. Mother's Pride Education Personna (P) Ltd. It (society) applied for registration under section 12AA which was denied by CIT(E) on the ground that assessee was not imparting education. Held: As evident, concerned franchise agreement did not speak of running a primary school. The Mother's Pride chain was that of a playschool and running a playschool, did not fit into the concept of education. Despite claim of upgradation (up to Fifth Standard) with effective from 1-4-2017, no evidence with regard thereto had been furnished. Accordingly, denial of registration under section 12AA was justifed.
Relied:Sole Trustee, Lok Sikshan Sansthan Trust v. CIT (1975) 101 ITR 234 (SC) : 1975 TaxPub(DT) 344 (SC).
REFERRED :
FAVOUR : Against the assessee.
A.Y. :
IN THE ITAT, AMRITSAR BENCH
 SUBSCRIBE FOR FULL CONTENT
|