On writ the High Court held that merely the receipts from donors who deducted tax at source it cannot be assessed as trade receipts. Principle of consistency was followed and held that the assessee was Entitle to exemption and the rejection of revisional order was set aside. SLP of revenue was dismissed.
CIT v. Aroh Foundation (2025) 476 ITR 504/304 Taxman 600 (SC) Editorial : Aroh Foundation v. CIT [2024] 159 taxmann.com 608/ (2025) 476 ITR 489 (Delhi)(HC)
S. 264 :Commissioner-Revision of other orders-Property held for charitable purposes-Receipts from donors who deducted tax at source-No element of trade-Principle of consistency-Entitle to exemption-Rejection of revisional order was set aside-SLP of revenue dismissed. [S. 2(15) 11, 12,12A, 12AA, 13(8),80G, 194C, 194J, Art. 136]