ITAT allowed the assessees appeal and granted exemption under...

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.