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    <title>2025 (5) TMI 1640 - ITAT BANGALORE</title>
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    <description>The ITAT Bangalore held that a trust&#039;s exemption under section 11 was not available for unaccounted cash receipts constituting capitation fees collected for medical college management seats. The tribunal determined that despite being labeled as &quot;management fees,&quot; these payments were capitation fees in nature. Following precedents from Madras HC and Delhi HC, the court ruled that capitation fees do not qualify as charitable activities under sections 11 and 12. Student affidavits denying capitation fee payments were deemed irrelevant as individuals would not make statements against their own interests. The revenue&#039;s appeals were allowed, denying the trust&#039;s tax exemption claim.</description>
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      <title>2025 (5) TMI 1640 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=771368</link>
      <description>The ITAT Bangalore held that a trust&#039;s exemption under section 11 was not available for unaccounted cash receipts constituting capitation fees collected for medical college management seats. The tribunal determined that despite being labeled as &quot;management fees,&quot; these payments were capitation fees in nature. Following precedents from Madras HC and Delhi HC, the court ruled that capitation fees do not qualify as charitable activities under sections 11 and 12. Student affidavits denying capitation fee payments were deemed irrelevant as individuals would not make statements against their own interests. The revenue&#039;s appeals were allowed, denying the trust&#039;s tax exemption claim.</description>
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      <pubDate>Tue, 22 Apr 2025 00:00:00 +0530</pubDate>
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