PR. COMMISSIONER OF vs. M/S. EMBASSY CHARITABLE TRUST
In the result, the appeal fails and is hereby dismissed
ITA/458/2019HC Karnataka27 Jan 2022
Bench: ALOK ARADHE,M.G.S. KAMAL
Section 12ASection 260Section 80GSection 80G(5)(vi)
housing which is commercial in nature and not
charitable in nature. It was further held that clause 3(v) of
the Trust Deed promotes industrial and commercial activities
and is therefore not charitable in nature. It was also held
that clause 5 of the Trust Deed gives an absolute discretion
to the trustees to sell and convert trust funds
