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    <title>2026 (6) TMI 87 - ITAT MUMBAI</title>
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    <description>Receipts from letting a trust&#039;s hall and auditorium were treated as incidental to its charitable objects, not as business income, because the trust was engaged predominantly in education and relief-oriented activities and the income was applied to charitable purposes. The quantum of such receipts alone was held insufficient to establish a commercial activity or an independent profit motive. The Revenue&#039;s reliance on the proviso to section 2(15) was rejected because the trust fell within the primary charitable limbs rather than the residuary category of general public utility. On that basis, section 11(4A) and the proviso to section 2(15) were held inapplicable and exemption under section 11 was allowed.</description>
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      <description>Receipts from letting a trust&#039;s hall and auditorium were treated as incidental to its charitable objects, not as business income, because the trust was engaged predominantly in education and relief-oriented activities and the income was applied to charitable purposes. The quantum of such receipts alone was held insufficient to establish a commercial activity or an independent profit motive. The Revenue&#039;s reliance on the proviso to section 2(15) was rejected because the trust fell within the primary charitable limbs rather than the residuary category of general public utility. On that basis, section 11(4A) and the proviso to section 2(15) were held inapplicable and exemption under section 11 was allowed.</description>
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