Dismissing the appeal the Court held that the Department could not controvert the fact that the assessee had not charged any fee from clients except the cost of the project actually incurred. Even in the sanction letter of grant to the assessee, there was mention of supervision or monitoring of activities by the donor, but that in itself was not sufficient to hold that any profit motive was involved. (AY.2011-12)
CIT v. Professional Assistance for Development Action (2022) 447 ITR 103 (Delhi)(HC)
S. 11 : Property held for charitable purposes-Rule of consistency-No change in activities-Supervision or monitoring of activities by donor not sufficient to hold that any profit motive is involved-Grant of exemption is valid. [S. 2(15)]