https://www.taxtmi.com/caselaws?id=787083 The note clarifies that Section 13(2)(e) read with Section 13(3) requires the statutory 'substantial interest' threshold to be met by the specific person referred to in Section 13(3), and that separate juristic identity prevents automatic attribution of shareholdings among distinct persons or entities. Aggregation of holdings of independent persons, an HUF and a corporate without satisfying the statutory tests cannot trigger disqualification of charitable exemption; accordingly denial of exemption under Sections 11 and 12 based on such aggregation is unsustainable. en-us Fri, 06 Feb 2026 00:00:00 +0530 Tue, 24 Feb 2026 12:32:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787083 The note clarifies that Section 13(2)(e) read with Section 13(3) requires the statutory 'substantial interest' threshold to be met by the specific person referred to in Section 13(3), and that separate juristic identity prevents automatic attribution of shareholdings among distinct persons or entities. Aggregation of holdings of independent persons, an HUF and a corporate without satisfying the statutory tests cannot trigger disqualification of charitable exemption; accordingly denial of exemption under Sections 11 and 12 based on such aggregation is unsustainable. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787083