Charitable status and Section 11 exemption sustained despite seminar fees and allied activity receipts.

Receipt of seminar and allied activity fees did not alter the institution's essential charitable character, because it continued to promote awareness and disseminate information on the automobile industry. The proviso to Section 2(15) was held inapplicable since the receipts did not show that the assessee had ceased to exist for charitable purposes. On that basis, exemption under Section 11 was maintained and the Revenue's challenge failed.

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Issues: Whether the assessee was entitled to exemption under Section 11 of the Income-tax Act, 1961 despite receipt of fees for seminars and allied activities, and whether the proviso to Section 2(15) was attracted so as to deny charitable status.

Analysis: The assessee was engaged in promoting awareness and disseminating information concerning the automobile industry. The collection of amounts towards seminars and similar activities was held not to alter the essential charitable character of the institution. The application of the proviso to Section 2(15) was rejected on the footing that the receipts did not show that the assessee had ceased to exist for charitable purposes.

Conclusion: The assessee remained entitled to exemption under Section 11, and the proviso to Section 2(15) did not disqualify it. The Revenue's challenge failed.

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