https://www.taxtmi.com/caselaws?id=449839 Delhi HC allowed writ petition challenging denial of exemption under Section 11. Revenue denied benefits solely because donor deducted TDS under Sections 194C and 194J while making grants. Court held TDS deduction by donor cannot be sole basis to deny exemption unless assessee specifically falls under proviso to Section 2(15). No element of trade, commerce or business activity existed. Revenue had consistently allowed similar exemptions in preceding and succeeding years without material change in facts. Principle of consistency in taxation matters required following same approach. Assessee entitled to exemptions under Sections 11 and 12. en-us Mon, 05 Feb 2024 00:00:00 +0530 Thu, 05 Jun 2025 10:45:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449839 Delhi HC allowed writ petition challenging denial of exemption under Section 11. Revenue denied benefits solely because donor deducted TDS under Sections 194C and 194J while making grants. Court held TDS deduction by donor cannot be sole basis to deny exemption unless assessee specifically falls under proviso to Section 2(15). No element of trade, commerce or business activity existed. Revenue had consistently allowed similar exemptions in preceding and succeeding years without material change in facts. Principle of consistency in taxation matters required following same approach. Assessee entitled to exemptions under Sections 11 and 12. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449839