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Charitable payment-system infrastructure operated for public benefit remained eligible for exemption under sections 11 and 12 despite transaction-based fees and surplus generation. Fee collection did not by itself establish commercial activity under the proviso to section 2(15), particularly where services were uniformly available at the same fee. No application of income for the benefit of specified persons was established under section 13(3). On identical facts to an earlier coordinate Bench ruling, exemption was sustained for both assessment years and the Revenue's appeals were dismissed.
Charitable payment-system infrastructure operated for public benefit remained eligible for exemption under sections 11 and 12 despite transaction-based fees and surplus generation. Fee collection did not by itself establish commercial activity under the proviso to section 2(15), particularly where services were uniformly available at the same fee. No application of income for the benefit of specified persons was established under section 13(3). On identical facts to an earlier coordinate Bench ruling, exemption was sustained for both assessment years and the Revenue's appeals were dismissed.
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