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        <h1>Tribunal Upholds Trust's Tax Exemption for Charitable Activities</h1> <h3>Director of Income Tax Exemptions, Chennai Versus M/s. Shanmuga Arts, Science, Technology & Research Academy (SASTRA)</h3> Director of Income Tax Exemptions, Chennai Versus M/s. Shanmuga Arts, Science, Technology & Research Academy (SASTRA) - [2021] 436 ITR 633 (Mad) Issues Involved:1. Applicability of exemption under Section 11 of the Income Tax Act.2. Interpretation of the Trust deed regarding the objects and activities of the trust.3. Classification of the trust as a public charitable trust.4. Treatment of donations made by the trust to related individuals, political parties, and others.5. Requirement of withdrawal of registration under Section 12AA for denial of exemption under Section 11.Issue-wise Detailed Analysis:1. Applicability of Exemption under Section 11:The central issue was whether the trust was entitled to claim exemption under Section 11 of the Income Tax Act, 1961. The Assessing Officer initially denied the exemption, treating all donations as non-exempt. However, the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal (ITAT) concluded that the trust's income applied to charitable or religious purposes in India is entitled to exemption under Section 11(1)(a). The Tribunal referenced the Andhra Pradesh High Court's decision, stating that even if the trust's objects do not explicitly empower certain expenditures, they are still entitled to exemption if applied for charitable or religious purposes.2. Interpretation of the Trust Deed:The Tribunal held that the trust deed dated 19.04.1984 was relevant to conclude the trust's objects and activities. The Assessing Officer's contention that the trust's donations deviated from its educational objects was rejected. The Tribunal emphasized that the trust's income must be applied or accumulated for application as per the Income Tax Act, irrespective of the specific objects in the trust deed.3. Classification as a Public Charitable Trust:The Tribunal upheld that the trust was a public charitable trust, as evidenced by the trust deed and supplementary deeds. The trust's activities, including running an educational institution as a deemed university, were consistent with its classification as a public charitable trust under Section 2(15) of the Act. The Tribunal concluded that charging fees for educational services does not disqualify the trust from being considered a public charitable trust.4. Treatment of Donations:The Assessing Officer initially disallowed the entire exemption for donations but later accepted most donations except for Rs. 14,94,886/-. The Tribunal found that the donations were made to charitable and religious institutions, and the philanthropy was evident. The Tribunal agreed with the Commissioner of Income Tax (Appeals) that the Assessing Officer's partial acceptance of donations contradicted her initial stance. The Tribunal concluded that donations for charitable purposes, even if not strictly within the trust's objects, are entitled to exemption under Section 11.5. Requirement of Withdrawal of Registration under Section 12AA:The Tribunal concurred with the Commissioner of Income Tax (Appeals) that the Assessing Officer lacked jurisdiction to deny exemption under Section 11 without referring the matter for withdrawal of registration under Section 12AA(3). The Tribunal emphasized that the proper procedure was not followed by the Assessing Officer.Conclusion:The Tribunal dismissed the Revenue's appeal, affirming the orders of the Commissioner of Income Tax (Appeals) and the ITAT. The Tribunal found no perversity in the lower authorities' orders and upheld that the trust was entitled to exemption under Section 11. The substantial questions of law raised by the Revenue were answered against them, and the appeal was dismissed with no order as to costs.

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