Exemptions u/s 11 and 12 - Charitable activity u/s 2(15) - The...

Exemptions u/s 11 and 12 - Charitable activity u/s 2(15) - The assessee trust is carrying out the activities of general utility of development of infrastructure for world class gem and jewellery in Surat. Now, on insertion of First Proviso to section 2(15), the benefit of section 11 cannot be deprived as the assessee is not carrying out any trade, commerce or business and only deals with its members to attain its objects. Therefore, it cannot be considered as an entity carrying out business under the guise of charity, as referred at para 3.2 of aforesaid CBDT Circular. - The object of the assessee is of general public utility and does not hit by first proviso to section 2(15) of the Act. - AT