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    <title>2025 (6) TMI 1739 - ITAT MUMBAI</title>
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    <description>The ITAT Mumbai held that a charitable trust registered under section 12A was entitled to exemption under section 11 of the Income Tax Act. The AO had denied the exemption by applying the principle of mutuality and the first proviso to section 2(15), arguing the assessee operated as a mutual association providing services for fees. The tribunal found the trust conducted activities for general public utility, including free annual events benefiting insurance consumers and brokers, not exclusively for members. The principle of mutuality was deemed inapplicable as the trust engaged in charitable activities for public benefit. The proviso to section 2(15) was also held inapplicable since no trade, commerce, or business activities for consideration were established. The appeal was allowed and additions deleted.</description>
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    <pubDate>Wed, 13 Nov 2024 00:00:00 +0530</pubDate>
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      <title>2025 (6) TMI 1739 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=773626</link>
      <description>The ITAT Mumbai held that a charitable trust registered under section 12A was entitled to exemption under section 11 of the Income Tax Act. The AO had denied the exemption by applying the principle of mutuality and the first proviso to section 2(15), arguing the assessee operated as a mutual association providing services for fees. The tribunal found the trust conducted activities for general public utility, including free annual events benefiting insurance consumers and brokers, not exclusively for members. The principle of mutuality was deemed inapplicable as the trust engaged in charitable activities for public benefit. The proviso to section 2(15) was also held inapplicable since no trade, commerce, or business activities for consideration were established. The appeal was allowed and additions deleted.</description>
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