Dismissing the appeal of the revenue the Court held that merely because the objects of the trust were for the advancement of the business of third party administrators, it would not ipso facto render the trust non-charitable. The objects of the trust were not exclusively for the promotion of the interests of the third party administrator members. The objects were to provide benefit to the general public in the field of insurance and health facilities. In the course of carrying out the main activities of the trust, the fact that benefits accrued to the third party administrator members could not, by itself, deny the institution the benefit of being a charitable organisation. The assessee-institution was entitled to registration under S. 12AA . (Referred, Addl CIT v. Surat Art Silk Cloth Manufacturers Association ( 1980) 121 ITR 1(SC), DIT v. Bharat Diamond Bourse(2003) 259 ITR 280 (SC)
CIT(E) v. Association of third party Administrators (2020) 426 ITR 108 /313 CTR 2 / 269 Taxman 579 (Delhi)(HC)
S. 12AA : Procedure for registration –Trust or institution-
Association of third party administrators — Dominant purpose of Institution Charitable — Ancillary purposes not charitable —Entitled to registration [ S.(2(15) ]