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ITAT held that the trust's loan from a related party was for legitimate charitable purposes, not for earning interest income. The tribunal admitted additional evidence demonstrating the loan's application towards trust's charitable objectives. The case was remanded to the CIT(E) to re-examine: (1) loan utilization for charitable expenses, and (2) verify the percentage of Parsi community beneficiaries. The assessee's appeal was allowed for statistical purposes, with directions to conduct a fresh assessment considering the submitted financial documentation and charitable intent.
ITAT held that the trust's loan from a related party was for legitimate charitable purposes, not for earning interest income. The tribunal admitted additional evidence demonstrating the loan's application towards trust's charitable objectives. The case was remanded to the CIT(E) to re-examine: (1) loan utilization for charitable expenses, and (2) verify the percentage of Parsi community beneficiaries. The assessee's appeal was allowed for statistical purposes, with directions to conduct a fresh assessment considering the submitted financial documentation and charitable intent.
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