Section 11 Exemption: Clarifying When Fees and Income Indicate Business Over Charity for Self-Sustaining Organizations.

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....Exemption u/s 11 - charitable or commercial activities - Fee charged and the quantum of income earned can be indicative of the fact that the person is carrying on the business or commerce and not charity - The petitioner has to be substantially self-sustaining in long-term and should not depend upon the Government, in other words, taxpayers should not subsidize the said activities, which nevertheless are charitable and fall under the residuary clause "general public utility". - AT....