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Corporate TaxArticle·22 February 2026

Dominant Purpose Doctrine

By JustIDT

Executive Summary

Doctrine of Dominant Purpose. The dispute centered on whether the petitioner society, engaged in running educational institutions, could be denied exemption on the ground that it was earning franchise fees from schools operating under its aegis, and whether such receipts amounted to business income disentitling it from exemption.

Introduction

The judgment arises out of W.P.(C) 9847/2009 and W.P.(C) 9848/2009 decided by the High Court of Delhi on 12 Feb...

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