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The HC upheld the ITAT's decision allowing the renewal of Section 80G approval for the assessee trust, rejecting the revenue's contention that fee collection rendered activities commercial and ineligible. The court found no statutory requirement that donations to non-80G-registered schools disqualify the trust, as such schools conducted charitable educational activities. Expenditures on operational costs were deemed legitimate and not a ground to deny exemption. The trust's consistent charitable activities since inception were noted, with no material change justifying refusal of renewal. Political donations, although impermissible, warranted a proportional deduction from the 85% charitable expenditure requirement rather than outright denial of Section 80G benefits. Consequently, the trust's renewal application was validly approved, affirming the trust's entitlement to exemption benefits under the Income Tax Act.
The HC upheld the ITAT's decision allowing the renewal of Section 80G approval for the assessee trust, rejecting the revenue's contention that fee collection rendered activities commercial and ineligible. The court found no statutory requirement that donations to non-80G-registered schools disqualify the trust, as such schools conducted charitable educational activities. Expenditures on operational costs were deemed legitimate and not a ground to deny exemption. The trust's consistent charitable activities since inception were noted, with no material change justifying refusal of renewal. Political donations, although impermissible, warranted a proportional deduction from the 85% charitable expenditure requirement rather than outright denial of Section 80G benefits. Consequently, the trust's renewal application was validly approved, affirming the trust's entitlement to exemption benefits under the Income Tax Act.
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