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Denial of charitable exemption turned on whether the appellant's activities were charitable or primarily professional advisory services and on retention of donations vis-a -vis the applicable monetary threshold for incidental commercial activity. The court accepted the Assessing Officer's arithmetic of total donations and retained amount against the monetary threshold from precedent, found no retention but a deficit in the relevant years, and concluded that exemption for charitable purpose should not be denied. Both substantive questions for the year were decided for the assessee and the appeal was allowed without remand.
Denial of charitable exemption turned on whether the appellant's activities were charitable or primarily professional advisory services and on retention of donations vis-a -vis the applicable monetary threshold for incidental commercial activity. The court accepted the Assessing Officer's arithmetic of total donations and retained amount against the monetary threshold from precedent, found no retention but a deficit in the relevant years, and concluded that exemption for charitable purpose should not be denied. Both substantive questions for the year were decided for the assessee and the appeal was allowed without remand.
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