Charitable Entity Maintains Status: Predominant Objective Key to Section 2(15) and 11 Exemption, Says Tax Commissioner.

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....Exemption u/s.11 - Charitable activity u/s 2(15) - it is fairly settled legal position that it is the pre-dominant objective which would be relevant to examine the applicability of proviso to Sec.2(15). The Ld. CIT(A) after examining the primary objects of the assessee as well as the purpose for which it was established, came to a conclusion that the primary objective was charitable in nature and collection of fees was not to earn profit. Therefore, the assessee did not cease to be charitable in character so as to render it ineligible to claim benefits u/s 11 and 12. - AT....