Proviso to Section 2(15) Inapplicable to Solar Energy Promotion Activities: ITAT Delhi

National Solar Energy Federation of India (NSEFI) Vs ITO (ITAT Delhi) The appeal before the ITAT Delhi concerned the denial of exemption under sections 11 and 12 of the Income Tax Act, 1961 for Assessment Year 2017–18. The assessee, a society registered under section 12AA, had filed its return declaring nil income. During the year, it received voluntary contributions amounting to ₹78,63,150, which were treated by the Assessing Officer as “annual membership fees in lieu of services” and not as charitable donations. On this basis, the Assessing Officer applied the proviso to section 2(15...