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Bench: Sh. Sanjay Arora & Sh. N. K. Choudhryi.T.A. No. 618/Asr/2017 Assessment Year: 2014-15
trust, could only be regarded as an application of its’ income by the donor trust/institution for its objects and, thus, for charitable purposes. That is, is charity by implication, or inference. The actual activity (which we may term as charity per se) would, it may be appreciated, only be when the income is utilized by the recipient