Registration under s.12AA was denied because the applicant's...

Registration under s.12AA was denied because the applicant's stated objects and actual activities were predominantly software development and start-up consultancy, which did not fall within any limb of "charitable purpose" under s.2(15). The authority further held that the applicant's dominant financing from a commercial entity, linked to strategic advisory arrangements, did not constitute income eligible for exemption under ss.11-12, as the receipts were in substance consideration for commercial services. In the absence of any material rebutting these findings, the denial of registration was upheld and the appeal was dismissed - ITAT

---