Charitable-object qualification of assessee's activities u/s2(15) and tax exemption of interest and corpus donations upheld
X X X X Extracts X X X X
X X X X Extracts X X X X
....Whether the assessee's activities qualified as "charitable purpose" under s.2(15) and thus exemption under s.11: tribunal held that registration u/s 12A creates a presumption of charitable objects unless contrary to s.2(15) or ss.13(1)(c)/(d); passive interest from mandated investments u/s11(5) is not commercial activity and does not attract the proviso to s.2(15), relying on jurisdictional precedent, therefore interest income remains exempt under s.11 - outcome: exemption upheld and additions deleted. Whether corpus donations are taxable: corpus receipts are capital and exempt u/s11(1)(d); no material for s.13 breach - outcome: exemption maintained. - ITAT....
TaxTMI