| Case ID |
2b2e7254-a488-46e1-b600-56df0424b169 |
| Body |
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| Case Number |
D-2741 of 1987 |
| Decision Date |
Dec 01, 1987 |
| Hearing Date |
Nov 15, 1987 |
| Decision |
The Tribunal correctly held that the assessee, the Andhra Pradesh Riding Club, was entitled to exemption under section 11(1)(a) of the Income-tax Act, 1961. The court emphasized that the club's activities, including the promotion of equestrian sports and training in horsemanship, served a charitable purpose and contributed to public utility. The court found that while the club conducted races, this was incidental to its primary charitable aim of providing training and promoting riding sports. The income generated was used to further these charitable objectives rather than for profit-making activities. Therefore, the club's activities did not fall under the exclusionary clause of 'not involving carrying on of any activity for profit'. |
| Summary |
The case of Commissioner of Income Tax v. Andhra Pradesh Riding Club revolves around the club's claim for tax exemption under section 11(1)(a) of the Income-tax Act, 1961. The club aimed to promote equestrian sports and provide horsemanship training, which was deemed a charitable purpose. The Income Tax Officer initially disallowed the exemption, arguing that the club's activities were profit-oriented due to their exclusivity to members. However, the Tribunal ruled in favor of the club, stating that the activities served the general public's interest in health and well-being. The court highlighted that the club's primary goal was not profit-making but rather to foster equestrian sports for public benefit. This case underscores the interpretation of charitable purposes under tax law and the balance between generating income and serving public utility. Keywords: tax exemption, charitable purpose, equestrian sports, public utility, Income-tax Act. |
| Court |
High Court of Andhra Pradesh
|
| Entities Involved |
Andhra Pradesh Riding Club
|
| Judges |
K. Ramaswamy,
M.N. Rao
|
| Lawyers |
M. Suryanarayanamurthy,
A.V.K. Koundinya,
Y. Ratnakar
|
| Petitioners |
Commissioner of Income Tax
|
| Respondents |
Andhra Pradesh Riding Club
|
| Citations |
1987 SLD 3496,
(1987) 168 ITR 393
|
| Other Citations |
Scottish Flying Club Ltd. v. IRC,
CIT v. Ootacamund Gymkhana Club [1977] 110 ITR 392 (Mad.),
Cricket Association of Bengal v. CIT [1959] 37 ITR 277 (Cal.),
CIT v. Andhra Chamber of Commerce [1965] 55 ITR 722 (SC),
CIT v. Andhra Pradesh Police Welfare Society [1984] 148 ITR 287 (AP)
|
| Laws Involved |
Income-tax Act, 1961
|
| Sections |
11(1)(a),
2(15)
|