Exemption u/s 11 - Assessee cannot be equated by with the...

Exemption u/s 11 - Assessee cannot be equated by with the private entrepreneur or coloniser or club or Association, as it is a state under Article 12 of the Constitution of India and has duties, towards all the citizens and resident of the area irrespective of caste, creed, religion, sex etc . The charging of cess or fees by the assessee is only an incidental activities to the main and primary activities of the assessee ,continues to be development etc for the benefit of general public - Activities of the assessee were driven by the its obligation under the Act, which were not neither trade nor commerce nor business and the charging of fees et cetera is only an incidental element for fulfilment of its obligation under the Act. - AT

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