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ITAT held that the assessee, a sports-focused charitable trust, qualifies for exemption under section 11 of the Income Tax Act. Despite the proviso to section 2(15), the tribunal found that the trust's activities are not commercial in nature, as it operates with consistent financial deficits and primarily promotes sports as a public utility. The trust's nominal charges merely cover operational costs, and its four-decade-long commitment to charitable objectives demonstrates no profit-making intention. Consequently, the tribunal rejected the revenue's arguments, allowing the exemption claim and dismissing the grounds raised by the revenue.
ITAT held that the assessee, a sports-focused charitable trust, qualifies for exemption under section 11 of the Income Tax Act. Despite the proviso to section 2(15), the tribunal found that the trust's activities are not commercial in nature, as it operates with consistent financial deficits and primarily promotes sports as a public utility. The trust's nominal charges merely cover operational costs, and its four-decade-long commitment to charitable objectives demonstrates no profit-making intention. Consequently, the tribunal rejected the revenue's arguments, allowing the exemption claim and dismissing the grounds raised by the revenue.
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