Registration Granted: Fees & Surplus Don’t Nullify Charitable Trust Status (Sec. 12A)

Thavam Research Foundation Vs CIT (Exemption) (ITAT Chennai)

Assessee, Thavam Research Foundation, challenged the order of CIT (Exemption), Chennai, rejecting its application for registration u/s 12A on the ground that its tie-up with Bharathidasan University for conducting diploma courses in acupuncture was commercial in nature.  CIT(E) treated the 30:70 fee-sharing arrangement as a franchise model &  denied registration.

Tribunal noted that the MoU was an educational collaboration, not a business franchise, &  that fee-sharing did not al

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