top of page

BLOG
Don’t raise your voice, improve your argument.
- Desmond Tutu-
Search


Foreign Membership and Software Payments Used for Charitable Activities in India Do Not Violate Section 11(1)(c): ITAT
In ASCI v. CIT, the Mumbai ITAT ruled that foreign remittances for software subscriptions and international memberships used to support domestic consumer-awareness and regulatory tasks do not violate Section 11(1)(c). Because the ultimate benefit and utilization of these expenses remain within India, they cannot be classified as income applied abroad. Additionally, the Tribunal ordered tax authorities to re-evaluate registration delays using historical Section 80G approvals.
Harshita Joshi and Dohit Muranjan
Jun 152 min read


Pre-School and Kindergarten Activities Constitute ‘Education’; Registration under Section 12AB Cannot Be Denied on Alleged Section 13 Violations: ITAT
The ITAT Chandigarh ruled that pre-school and kindergarten activities constitute “education” under Section 2(15) of the Income-tax Act, recognizing Early Childhood Care and Education (ECCE) as part of the formal education system. It held that registration under Section 12AB cannot be denied based on alleged Section 13 violations, as such issues must be examined during assessment proceedings. The Tribunal directed the tax authorities to grant charitable registration to the ass
Harshita Joshi and Dohit Muranjan
Jun 152 min read


Corpus Fund vs Unrestricted Reserves: Understanding the Difference
Many NGOs mistakenly treat accumulated funds as corpus, but corpus funds and unrestricted reserves are fundamentally different. Corpus funds arise from donor-specific directions and must follow investment and tax rules, while unrestricted reserves come from organisational surpluses and offer operational flexibility. Correct classification is essential for compliance, reporting, and governance.
Dohit Muranjan & Akansha Dange
Jun 154 min read


Predominant Charitable Activities Cannot Be Denied Exemption Merely Due to Religious Elements: ITAT
In the case of Assistant Commissioner of Income-tax (Exemption) v. Shri Khodal Dham Trust, the ITAT Ahmedabad ruled that a trust's predominant charitable activities could not be deemed non-exempt just due to religious elements. The trust, engaged in education, medical relief, and public welfare, constructed a prayer hall and conducted rituals. The Assessing Officer denied exemptions, citing religious bias. The Tribunal highlighted that activities were open to all, and judicia
Harshita Joshi and Dohit Muranjan
May 252 min read
bottom of page

