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ITAT allowed the assessees appeal and granted exemption under s.11, overturning the CIT(A)'s denial. The Tribunal held that the assessee could not be penalised for absence of a contemporaneous s.12A/12AA registration certificate when a subsequent certificate covering AY 2022-23 to 2026-27 was produced and the factual matrix matched a prior bench decision in the assessees favour. Corpus contributions were characterised as voluntary donations and, on the facts, the assessee applied 87.87% of receipts to charitable purposes. Receipts for medical services were held non-commercial and below the 20% threshold, so the proviso to s.2(15) did not apply; appeal was allowed.
ITAT allowed the assessees appeal and granted exemption under s.11, overturning the CIT(A)'s denial. The Tribunal held that the assessee could not be penalised for absence of a contemporaneous s.12A/12AA registration certificate when a subsequent certificate covering AY 2022-23 to 2026-27 was produced and the factual matrix matched a prior bench decision in the assessees favour. Corpus contributions were characterised as voluntary donations and, on the facts, the assessee applied 87.87% of receipts to charitable purposes. Receipts for medical services were held non-commercial and below the 20% threshold, so the proviso to s.2(15) did not apply; appeal was allowed.
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