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    <title>2026 (5) TMI 90 - ITAT DELHI</title>
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    <description>Exemption under sections 11 and 12 was denied where search material showed that the assessee&#039;s bank account and related documents were used in a coordinated routing of funds with FIIT JEE Group. The Tribunal found that the assessee was a participant in the arrangement, had allowed funds to move through its account and then be shown as application of income for charitable purposes, and could not shift the tax consequence entirely to the other group by describing itself as a mere conduit. The addition sustained by the Assessing Officer and the Commissioner (Appeals) was therefore upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790888</link>
      <description>Exemption under sections 11 and 12 was denied where search material showed that the assessee&#039;s bank account and related documents were used in a coordinated routing of funds with FIIT JEE Group. The Tribunal found that the assessee was a participant in the arrangement, had allowed funds to move through its account and then be shown as application of income for charitable purposes, and could not shift the tax consequence entirely to the other group by describing itself as a mere conduit. The addition sustained by the Assessing Officer and the Commissioner (Appeals) was therefore upheld.</description>
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