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ITAT addressed exemption under Section 11 for a public charitable trust. The tribunal examined whether sale of devotional articles constitutes a business activity disqualifying tax exemption. Despite revenue's argument that surplus income from sales negates exemption, ITAT found the trust's primary activities remained charitable, including feeding poor, providing education, and medical relief. The tribunal noted majority of income derived from donations and interest. Referencing SC precedent, ITAT determined sales at nominal cost do not automatically transform charitable activities into business. Administrative expenses and overall charitable objectives were considered. CIT(A)'s original exemption was upheld, and revenue's appeal was dismissed.
ITAT addressed exemption under Section 11 for a public charitable trust. The tribunal examined whether sale of devotional articles constitutes a business activity disqualifying tax exemption. Despite revenue's argument that surplus income from sales negates exemption, ITAT found the trust's primary activities remained charitable, including feeding poor, providing education, and medical relief. The tribunal noted majority of income derived from donations and interest. Referencing SC precedent, ITAT determined sales at nominal cost do not automatically transform charitable activities into business. Administrative expenses and overall charitable objectives were considered. CIT(A)'s original exemption was upheld, and revenue's appeal was dismissed.
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