Janmashtami Donations Not Business Income; ITAT Restores Section 11 Exemption to Religious Trust

Krishna Janmashtmi Mahotsav Samiti Vs ITO (ITAT Delhi) Delhi ITAT “A” Bench in held that donations received during religious functions like Janmashtami Mahotsav cannot be treated as business or advertisement income merely because donors’ names were displayed. The Assessee, a registered public charitable & religious trust u/s 12A and 80G, had declared NIL income claiming exemption u/ss 11 & 12. AO treated donations of ₹50.54 lakh as business income u/s 11(4A) on the ground that some donors, in replies u/s 133(6), indicated publicity/advertisement elements. NFAC upheld the additi...