Exemption under s 11

Exemption under s 11 cannot be denied to charitable trust/society merely because it is making systematic profit, even though the profit is utilised only for charitable purpose — as held by CuttackTrib in ITO v Silicon Institute of Technology — In favour of: The assessee.

The generation of surplus out of the fees collected would not indicate a profit motive.

Appeal (Tribunal) — The Tribunal may not give its reasons when it agrees with the reasoning given by the CIT(A).

Decided on: 23 September 2011.