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    <title>2023 (11) TMI 497 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai ruled in favor of a trust dedicated to Shri Sai Baba, holding that anonymous donations received were not taxable under section 115BBC. The tribunal determined the trust existed for both charitable and religious purposes, rejecting the revenue&#039;s narrow interpretation that excluded Hindu worship as religious activity. The court emphasized that religious purpose must be interpreted broadly and inclusively. The trust&#039;s approval under section 10(23C)(v) provided significant evidence of its dual charitable-religious nature. The tribunal allowed accumulation benefits under section 11(2) after delay in filing Form 10 was condoned, and directed proper calculation of accumulation limits. However, exemption for interest on corpus funds under section 11(1)(d) was denied as donors had not specifically directed interest toward corpus purposes.</description>
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    <pubDate>Wed, 25 Oct 2023 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=445606</link>
      <description>The ITAT Mumbai ruled in favor of a trust dedicated to Shri Sai Baba, holding that anonymous donations received were not taxable under section 115BBC. The tribunal determined the trust existed for both charitable and religious purposes, rejecting the revenue&#039;s narrow interpretation that excluded Hindu worship as religious activity. The court emphasized that religious purpose must be interpreted broadly and inclusively. The trust&#039;s approval under section 10(23C)(v) provided significant evidence of its dual charitable-religious nature. The tribunal allowed accumulation benefits under section 11(2) after delay in filing Form 10 was condoned, and directed proper calculation of accumulation limits. However, exemption for interest on corpus funds under section 11(1)(d) was denied as donors had not specifically directed interest toward corpus purposes.</description>
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