Case Law Analysis
|Income Tax Appellate Tribunal
Section 2(15) IT Act | Royalty & Sponsorship Income Not Business Income If Incidental to Charitable Purpose : ITAT Delhi
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.