#Section 2(15) IT Act

ITAT Delhi has ruled that even if an industry association earns commercial receipts, it retains eligibility for tax exemption under Section 11 if its core activities advance a General Public Utility, provided the 20% threshold is not exceeded. This clarifies that revenue nature alone cannot override statutory charitable intent - a critical precedent for trade bodies and professional societies seeking tax exemption.

The ITAT Delhi has ruled that charitable hospitals receiving payments from insurance companies remain eligible for tax exemption under Section 2(15) if their primary purpose is medical relief. This clarifies a critical ambiguity for nonprofit healthcare providers relying on third-party reimbursements, affirming that revenue source does not override charitable intent when services remain non-profit and publicly oriented.

ITAT Delhi rules that statutory urban development authorities like Hapur Pilukhuwa Development Authority qualify as charitable institutions under Section 2(15) of the Income Tax Act, entitling them to exemption under Section 11. The tribunal affirms that development activities for public purposes fall within the ambit of 'charitable purpose,' rejecting the Revenue's argument on commercial receipts.

The ITAT Delhi has ruled that royalty and sponsorship receipts earned by the Wrestling Federation of India are incidental to its charitable objectives under Section 2(15), and therefore not taxable as business income. This preserves the federation’s exemption under Sections 11 and 12, setting a critical precedent for national sports bodies relying on non-commercial funding to sustain public welfare activities.

ITAT Mumbai rules that a charitable trust's incidental income from agro, gaushala, and rental activities does not defeat its charitable purpose under Section 2(15) of the Income Tax Act if it remains below the 20% threshold. The decision reinforces that registration under Section 12AB cannot be denied solely on grounds of minor commercial income aligned with the trust's objects.