The predominant object of imparting Yoga training through well structured Yoga shivirs is to provide medical relief and impart education, which fall under the category of charitable objects defined under section 2(15).
The Tribunal held as under:
1) Yoga can be safely accepted as a system that fits into the definition of medical relief. As a science it is a well recognized system of medicine, which has therapeutic effects in treating serious ailments;
2) The predominant objective of the assessee-trust was to provide medical relief through Ayurveda and propagation of Yoga for the purpose of curing various diseases;
3) Any form of educational activity involving imparting of systematic training, to develop the knowledge, skill, mind and character of students is to be regarded as 'education', covered under section 2(15);
4) Thus, imparting of Yoga training through well structured Yoga shivirs would fall under the category of imparting education, which is one of the charitable objects defined under section 2(15);
5) The various other objectives of assessee-trust were merely ancillary to its main object, which was to provide medical relief and impart education and would not in any way constitute objectives of general public utility;
6) The proviso to section 2(15) applies only to trusts falling in the last limb of the definition of charitable purpose, that too if such trust carries on commercial activities in the nature of business, trade or commerce. The said proviso does not apply to a trust providing education and medical relief. Thus, revenue was not justified in refusing the exemption claimed by assessee-trust under sections 11 and 12 - DIVYA YOG MANDIR TRUST V. JCIT (2013) 37 taxmann.com 227 (Delhi - Trib.)
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