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    <title>2025 (12) TMI 1646 - ITAT MUMBAI</title>
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    <description>Whether exemption under s.11 could be denied by treating rental receipts from an auditorium/conference hall as profit-oriented business was examined. The Tribunal held that the audited accounts showed no surplus but a loss, and the AO erred in taxing gross receipts while ignoring undisputed expenditure incurred on educational and charitable activities, with no adverse finding on genuineness or application. Since only net income is taxable and the computation must allow legitimate expenses, no taxable income arose for the year. The addition made by taxing the gross receipts was directed to be deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784106</link>
      <description>Whether exemption under s.11 could be denied by treating rental receipts from an auditorium/conference hall as profit-oriented business was examined. The Tribunal held that the audited accounts showed no surplus but a loss, and the AO erred in taxing gross receipts while ignoring undisputed expenditure incurred on educational and charitable activities, with no adverse finding on genuineness or application. Since only net income is taxable and the computation must allow legitimate expenses, no taxable income arose for the year. The addition made by taxing the gross receipts was directed to be deleted.</description>
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