Topic

Section 2(15) Income Tax Act

3 articlesLatest May 2026
Section 2(15) IT Act | Fee-Based Environmental Education Programs Qualify as Charitable Activity Under Fifth Limb: ITAT Delhi
Case Law Analysis
|Income Tax Appellate Tribunal

Section 2(15) IT Act | Fee-Based Environmental Education Programs Qualify as Charitable Activity Under Fifth Limb: ITAT Delhi

The ITAT Delhi has ruled that an NGO earning fees for delivering environmental curricula to schools remains eligible for charitable registration under the fifth limb of Section 2(15), as long as its primary objective is public benefit, not profit. This clarifies that commercial receipts alone do not disqualify charitable status - a critical precedent for education and environmental nonprofits relying on sustainable funding models.

Section 2(15) Income Tax Act | Vocational & Skill Development Training Qualifies as 'Education' for Charitable Exemption: ITAT Bangalore
Case Law Analysis
|Income Tax Appellate Tribunal

Section 2(15) Income Tax Act | Vocational & Skill Development Training Qualifies as 'Education' for Charitable Exemption: ITAT Bangalore

The ITAT Bangalore has ruled that charitable trusts offering vocational and skill-based training meet the legal definition of 'education' under Section 2(15), making them eligible for income tax exemption under Section 11. This landmark decision expands the scope of charitable activities eligible for tax relief, directly benefiting NGOs and trusts running skill development programs across India.

Section 2(15) IT Act | Royalty & Sponsorship Income Not Business Income If Incidental to Charitable Purpose : ITAT Delhi
Case Law Analysis
|Income Tax Appellate Tribunal

Section 2(15) IT Act | Royalty & Sponsorship Income Not Business Income If Incidental to Charitable Purpose : ITAT Delhi

The ITAT Delhi has ruled that royalty and sponsorship receipts earned by the Wrestling Federation of India are incidental to its charitable objectives under Section 2(15), and therefore not taxable as business income. This preserves the federation’s exemption under Sections 11 and 12, setting a critical precedent for national sports bodies relying on non-commercial funding to sustain public welfare activities.