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In favour of assessee.The Ld. CIT(E) may also examine eligibility of the assessee for registration under the fourth limb of charitable purpose, i.e., advancement of general public utility in accordance with law, if raised so by the assessee. It is needless to mention that the assessee shall be afforded adequate opportunity of being heard.

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Section 2(15) read with section 12AA of the Income Tax Act, 1961 — Charitable purpose — Matter was to be readjudicated as Commissioner (Exemption) rejected a foundation's application under section 12AA on ground that it was engaged in providing coaching to IBBI aspirant students for examination preparation while he had not verified whether education imparted was in character of formal schooling or not as per section 2(15) — IOV Registered Valuers Foundation vs. Commissioner of income tax [2020] 180 ITD 1 (Delhi-trib)

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