https://www.taxtmi.com/caselaws?id=783810 The dominant issue was whether receipts labelled as "donations/membership fees" during religious events constituted commercial/advertisement income disentitling the trust to exemption under ss. 11-12 read with s. 2(15). The ITAT held the trust's objects were religious and cultural, not "general public utility," so the proviso to s. 2(15) was inapplicable; even otherwise, the disputed receipts were well below the statutory 20% threshold, so no disqualification arose, and exemption could not be denied. On characterisation, the Tribunal found the amounts were applied to declared religious activities and construction of a dharmshala, with donor name display being mere acknowledgment without profit motive or commercial benefit, hence not business consideration; the additions were deleted and the appeal was allowed. en-us Wed, 17 Dec 2025 00:00:00 +0530 Tue, 23 Dec 2025 07:59:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783810 The dominant issue was whether receipts labelled as "donations/membership fees" during religious events constituted commercial/advertisement income disentitling the trust to exemption under ss. 11-12 read with s. 2(15). The ITAT held the trust's objects were religious and cultural, not "general public utility," so the proviso to s. 2(15) was inapplicable; even otherwise, the disputed receipts were well below the statutory 20% threshold, so no disqualification arose, and exemption could not be denied. On characterisation, the Tribunal found the amounts were applied to declared religious activities and construction of a dharmshala, with donor name display being mere acknowledgment without profit motive or commercial benefit, hence not business consideration; the additions were deleted and the appeal was allowed. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783810