https://www.taxtmi.com/caselaws?id=770411 ITAT Mumbai held that a charitable trust promoting sports activities was entitled to exemption under section 11 despite the proviso to section 2(15). The trust operated swimming, squash, gymnasium, and other sports facilities with continuous deficits, charging nominal fees only to cover costs without profit intention. The court found that activities falling under "advancement of general public utility" remained charitable despite the proviso, as there was no commercial intent. The AO's application of mutuality principles was rejected since mutual activities cannot simultaneously constitute trade or business. The trust's four-decade history of charitable sports promotion for all communities supported the exemption claim. en-us Fri, 21 Mar 2025 00:00:00 +0530 Sat, 10 May 2025 08:36:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770411 ITAT Mumbai held that a charitable trust promoting sports activities was entitled to exemption under section 11 despite the proviso to section 2(15). The trust operated swimming, squash, gymnasium, and other sports facilities with continuous deficits, charging nominal fees only to cover costs without profit intention. The court found that activities falling under "advancement of general public utility" remained charitable despite the proviso, as there was no commercial intent. The AO's application of mutuality principles was rejected since mutual activities cannot simultaneously constitute trade or business. The trust's four-decade history of charitable sports promotion for all communities supported the exemption claim. Case-Laws Income Tax Fri, 21 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770411