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    <title>Denial of Exemption Under Sections 11 &amp;amp; 12 for Temple Due to Non-Filing and Conditions Not Met</title>
    <link>https://www.taxtmi.com/highlights?id=90671</link>
    <description>The ITAT upheld the denial of exemption under sections 11 and 12 of the I.T. Act to the assessee temple due to non-filing of return and failure to satisfy conditions under section 11. The Tribunal clarified that section 115BBC&#039;s tax rate on anonymous donations does not apply to the assessee as a religious trust; thus, donations collected under Hundi are to be assessed on net surplus basis under sections 56 and 57, not on gross receipts. Section 10(23BBA) was held inapplicable to the temple&#039;s income, as it applies only to income of the administrative authority appointed under the Endowment Act, not to the temple itself. The statutory payments to the authority are deductible from the temple&#039;s income. The decision aligns with precedent, confirming that public religious trusts/temples must seek exemption under sections 11 and 12, and cannot claim benefit under section 10(23BBA).</description>
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    <pubDate>Sat, 19 Jul 2025 14:48:58 +0530</pubDate>
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      <title>Denial of Exemption Under Sections 11 &amp;amp; 12 for Temple Due to Non-Filing and Conditions Not Met</title>
      <link>https://www.taxtmi.com/highlights?id=90671</link>
      <description>The ITAT upheld the denial of exemption under sections 11 and 12 of the I.T. Act to the assessee temple due to non-filing of return and failure to satisfy conditions under section 11. The Tribunal clarified that section 115BBC&#039;s tax rate on anonymous donations does not apply to the assessee as a religious trust; thus, donations collected under Hundi are to be assessed on net surplus basis under sections 56 and 57, not on gross receipts. Section 10(23BBA) was held inapplicable to the temple&#039;s income, as it applies only to income of the administrative authority appointed under the Endowment Act, not to the temple itself. The statutory payments to the authority are deductible from the temple&#039;s income. The decision aligns with precedent, confirming that public religious trusts/temples must seek exemption under sections 11 and 12, and cannot claim benefit under section 10(23BBA).</description>
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      <pubDate>Sat, 19 Jul 2025 14:48:58 +0530</pubDate>
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