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The ITAT allowed the assessee's appeal against denial of registration under section 12AB. The revenue contended that the assessee engaged only in commercial activities by collecting 10% management fees rather than charitable activities. The CIT(A) held the activities were business-oriented and commercial in nature, noting the assessee entered into an agreement with a private company before executing the parent agreement with NSDC. The ITAT held that for registration purposes under section 12A, the determinative factor is whether activities mentioned in the trust deed are charitable in nature, not the sequence of agreements. Finding the trust deed objects genuinely charitable, the ITAT directed the CIT(E) to grant registration under section 12A and consequential exemption under section 80G.
The ITAT allowed the assessee's appeal against denial of registration under section 12AB. The revenue contended that the assessee engaged only in commercial activities by collecting 10% management fees rather than charitable activities. The CIT(A) held the activities were business-oriented and commercial in nature, noting the assessee entered into an agreement with a private company before executing the parent agreement with NSDC. The ITAT held that for registration purposes under section 12A, the determinative factor is whether activities mentioned in the trust deed are charitable in nature, not the sequence of agreements. Finding the trust deed objects genuinely charitable, the ITAT directed the CIT(E) to grant registration under section 12A and consequential exemption under section 80G.
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