TDS or Invoice Can’t Kill Charity – ITAT Says ₹5.97 Cr Is Donation, Not Business Income

DCIT Vs ODIA Samaj (ITAT Delhi) Odia Samaj is a charitable trust registered u/s 12A & 80G. It organized a cultural event “Odisha Prabha” at India Gate in March 2019. For this event, it received ₹5,97,50,353/- from 11 organizations, which deducted TDS u/s 194C while remitting the amount. AO held that since TDS was deducted u/s 194C & invoices were issued, the receipts represented commercial activity / professional or contractual services, hit by proviso to section 2(15). He treated the receipts as business income & denied exemption u/s 11. He further added ₹1,04,20,000/- u/s...