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Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
ITAT held that at the stage of registration under section 12AB, enquiry is confined to the trust's objects and the genuineness of its activities, while issues of income application belong to assessment. It found the trust's procurement, processing and sale of rejected agricultural produce were intrinsically connected with relief of the poor and environmental protection, with surplus reinvested in charitable work. The tribunal rejected the view that purchase-sale accounts, salary , or CSR-funded receipts made the activity commercial, applying the predominant object test and noting no evidence of private profit. It set aside the rejection and directed grant of registration.
ITAT held that at the stage of registration under section 12AB, enquiry is confined to the trust's objects and the genuineness of its activities, while issues of income application belong to assessment. It found the trust's procurement, processing and sale of rejected agricultural produce were intrinsically connected with relief of the poor and environmental protection, with surplus reinvested in charitable work. The tribunal rejected the view that purchase-sale accounts, salary , or CSR-funded receipts made the activity commercial, applying the predominant object test and noting no evidence of private profit. It set aside the rejection and directed grant of registration.
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