The denial of exemption was justified demonstrating the fact that the trust was not existing for charitable purposes and was running schools and institutes on a commercial basis howvver donations made by the assessee to another charitable trust should be regarded as application of income towards the object of the trust. However, the Tribunal also held that the donations made by the assessee to another charitable trust should be regarded as application of income towards the object of the trust (ITA Nos. 1142 & 1214/Del/2011, 2675/Del/2013 / 2871, 2872/Del/2014 dt. 08-11-2017) (AY. 2007-08, 2009-10 , 2010-11)
IILM Foundation v. Addl. DIT(E) (2018) 61 ITR 186 (Delhi)(Trib.)
S. 11 : Property held for charitable purposes – The denial of exemption was held to be justified as the Trust was running schools and institutes on a commercial basis howvver donations made by the assessee to another charitable trust should be regarded as application of income towards the object of the trust. [S. 2(15) 13]