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of <h1>High Court upholds tax exemptions for charitable trust activities promoting education, agriculture, & cattle breeding</h1> <h3>PRINCIPAL COMMISSIONER OF INCOME TAX (EXEMPTIONS) Versus ANIMAL BREEDING RESEARCH ORGANISATION (INDIA)</h3> PRINCIPAL COMMISSIONER OF INCOME TAX (EXEMPTIONS) Versus ANIMAL BREEDING RESEARCH ORGANISATION (INDIA) - TMI Issues:1. Whether the Tribunal was justified in allowing exemptions u/s 11 of the Act without considering the commercial nature of the assessee's activitiesRs.2. Whether the assessee's activity of sale of semen falls within the definition of 'charitable purpose' under section 2(15) of the Income Tax Act, 1961Rs.Analysis:Issue 1: The Revenue appealed against the Tribunal's judgment, questioning the justification of allowing exemptions u/s 11 of the Act without considering the commercial nature of the assessee's activities. The assessee, a registered Trust, was involved in activities related to the development of cattle and buffaloes, including breeding and genetic improvement. The Assessing Officer argued that the significant income from the sale of semen indicated a commercial business motive, making it ineligible for charitable purpose status under section 2(15) of the Act.Issue 2: The Tribunal's decision was influenced by a previous judgment involving a similar trust, where the Court had emphasized the charitable nature of the trust's objectives related to cattle breeding, agricultural development, and educational initiatives. The Tribunal, citing this precedent and the judgment of the Division Bench in another case, rejected the Revenue's appeal. The Court highlighted the trust's activities aimed at public utility and charitable purposes, including breeding cattle, improving cattle quality, agricultural initiatives, and educational programs related to cattle keeping and agriculture.In conclusion, the High Court dismissed the Tax Appeal, affirming the Tribunal's decision to grant exemptions u/s 11 of the Act to the assessee Trust. The judgment emphasized the charitable nature of the trust's objectives and activities, aligning with the definition of charitable purpose under the Income Tax Act.
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