Court Avoids Fact-Finding in Charitable Status Case Under Income Tax Act Section 11 and Section 2(15) Framework.

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....Exemption u/s 11 - Whether activities of assessee are charitable in nature? - The critical issue continues to relate to the usage of funds by the petitioner as this would determine whether its activities are charitable or otherwise, This has then to be set and seen in the context of Section 2(15) of the Act. This exercise necessarily involves an appreciation of facts which this Court is not inclined to embark upon in terms of Article 226 of the Constitution of India. - HC....