I seek the views of professionals on the following issue under the Foreign Contribution (Regulation) Act, 2010.
A charitable trust in India proposes to organize an international conference and collect registration fees from both Indian and foreign participants.
Explanation 3 to the FCRA Act, 2010 appears to provide that fees collected towards participation in a seminar/conference shall not be treated as foreign contribution.
Further, Question No. 12 of the MHA FAQs also appears to provide a similar clarification.
In view of the above, can it be concluded that registration fees received from foreign participants for attending a conference/seminar in India would not constitute "foreign contribution" under the FCRA, and accordingly, FCRA registration/prior permission would not be required solely for receipt of such registration fees?
I would appreciate your views, particularly if supported by any statutory provisions, MHA clarifications, judicial precedents, or practical experience.