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of The HC upheld the findings of the NFAC and ITAT, affirming that the assessee lawfully accumulated less than 15% of its total receipts under section 11(1)(a) for specific purposes. The capital expenditure, including Rs. 3.14 crores accumulated previously and Rs. 2.89 crores utilized in the current year, was correctly treated as part of charitable activities. The outlay of Rs. 8.4 crores on the RO water treatment plant and Rs. 30 lakhs on solar lantern distribution were also held to be in furtherance of charitable purposes. The Revenue failed to demonstrate any error of law or perversity in the factual findings by NFAC and ITAT. Consequently, no substantial question of law arose, resulting in dismissal of the Revenue's appeal. The exemption under section 11 was thus confirmed.
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