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The HC upheld the ITAT's order allowing the assessee's claim for exemption under sections 11 and 12. Following its earlier decision in Indian Broadcasting Foundation [2025 (3) TMI 1124], the Court held that the application of funds in BARC did not qualify as "investment" under section 11(5) read with section 13(1)(d) of the Act. The Court determined that the deployment of funds was not intended to yield income, profit, or return, but was made pursuant to a statutory and regulatory obligation to further the assessee's charitable objectives. The questions of law were answered in favor of the assessee and against the Revenue, with the HC finding no infirmity in the ITAT's order.
The HC upheld the ITAT's order allowing the assessee's claim for exemption under sections 11 and 12. Following its earlier decision in Indian Broadcasting Foundation [2025 (3) TMI 1124], the Court held that the application of funds in BARC did not qualify as "investment" under section 11(5) read with section 13(1)(d) of the Act. The Court determined that the deployment of funds was not intended to yield income, profit, or return, but was made pursuant to a statutory and regulatory obligation to further the assessee's charitable objectives. The questions of law were answered in favor of the assessee and against the Revenue, with the HC finding no infirmity in the ITAT's order.
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