The ITAT allowed the appeal of the assessee Trust engaged in...

The ITAT allowed the appeal of the assessee Trust engaged in educational activities, holding that the denial of exemption under Section 11 was unwarranted as the AO failed to demonstrate violation of charitable objectives under Section 2(15). Disallowances under Section 13(1)(c) related to honorarium and travel expenses were set aside due to lack of proper scrutiny and consistent past treatment. Accumulated funds not applied within five years were protected under the proviso to Section 11(2) due to litigation-induced delay. Disallowances of AMC expenses and notional interest were reversed, recognizing preparatory educational activities as charitable. A minor donation to a religious institution was held not to breach the 85% application requirement. The AO's depreciation disallowance was also deleted, as the assessee's net expenditure exceeded income. Overall, the assessee was entitled to exemption under Sections 11 and 12, with all impugned additions and disallowances quashed.