https://www.taxtmi.com/caselaws?id=783059 ITAT Delhi dismissed the Revenue's appeal and upheld the CIT(A)'s order granting full relief to the assessee-society registered u/s 12AA. The Tribunal held that donations and charity were in line with the assessee's objects, advertisement and service payments to a related concern, royalty for brand use, and depreciation on branding and curriculum development were all incurred wholly for charitable purposes, with no material showing excessiveness or violation of s.13(1)(c) or 13(3). Ad hoc disallowances of various administrative and hostel-related expenses were rejected as arbitrary and unsupported by evidence. The AO's treatment of the assessee as an AOP was disapproved, and exemption/application of income u/ss 11 and 12 was confirmed. en-us Fri, 28 Nov 2025 00:00:00 +0530 Tue, 09 Dec 2025 08:41:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783059 ITAT Delhi dismissed the Revenue's appeal and upheld the CIT(A)'s order granting full relief to the assessee-society registered u/s 12AA. The Tribunal held that donations and charity were in line with the assessee's objects, advertisement and service payments to a related concern, royalty for brand use, and depreciation on branding and curriculum development were all incurred wholly for charitable purposes, with no material showing excessiveness or violation of s.13(1)(c) or 13(3). Ad hoc disallowances of various administrative and hostel-related expenses were rejected as arbitrary and unsupported by evidence. The AO's treatment of the assessee as an AOP was disapproved, and exemption/application of income u/ss 11 and 12 was confirmed. Case-Laws Income Tax Fri, 28 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783059