Universal Education Missions Trust vs. Income Tax Officer

Parties Involved

Facts Summary

The assessee, Universal Education Missions Trust, is a trust engaged in imparting education at the pre-primary, primary, and secondary levels. The trust filed its return of income for the assessment year 2015-16 on 17.03.2017, declaring nil income. The Centralized Processing Centre (CPC), Bengaluru, processed the return under section 143(1) of the Income-tax Act, 1961, and issued an intimation on 02.01.2018, disallowing the amount of Rs.1,01,83,461/- shown by the assessee as application of income towards its educational objects. Consequently, the entire amount was treated as taxable income. The assessee filed an appeal against the intimation, which was dismissed by the learned Commissioner of Income-tax (Appeals). The assessee then filed a further appeal before the Income Tax Appellate Tribunal (ITAT).…

Legal Issues

• 1. Whether the pre-primary, primary, and secondary sections operated by the assessee constitute independent educational institutions for applying the threshold prescribed under section 10(23C)(iiiad) of the Income-tax Act, 1961?
• 2. Whether the assessee is entitled to exemption under section 10(23C)(iiiad) of the Income-tax Act, 1961?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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