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    <title>2024 (6) TMI 920 - ITAT MUMBAI</title>
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    <description>A statutory welfare body was found entitled to exemption under sections 11 and 12 because it was registered for charitable exemption, applied more than 85% of its receipts to its objects, and invested surplus funds only in modes permitted by section 11(5); the appellate claim was not barred merely because it was omitted from the original return. Separately, the body was treated as an instrumentality of the State under Article 289 because it was created under State law and subjected to deep and pervasive governmental control in constitution, administration, financing and supervision, with public welfare functions. The Revenue&#039;s challenge failed on both issues.</description>
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      <title>2024 (6) TMI 920 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=754313</link>
      <description>A statutory welfare body was found entitled to exemption under sections 11 and 12 because it was registered for charitable exemption, applied more than 85% of its receipts to its objects, and invested surplus funds only in modes permitted by section 11(5); the appellate claim was not barred merely because it was omitted from the original return. Separately, the body was treated as an instrumentality of the State under Article 289 because it was created under State law and subjected to deep and pervasive governmental control in constitution, administration, financing and supervision, with public welfare functions. The Revenue&#039;s challenge failed on both issues.</description>
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