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Exemption u/s 11 and 12 - charitable activities - Assessee is acting as bridge between the donor and the donee - CIT(A) observed that the assessee receives fees from the donors as well as the donees - The assessee had further given the donation to other trusts for the purpose of carrying out charitable work itself would not disentitle the assessee from denial of exemption. - the matter is being restored to the file of the AO to analyse the impact of the observations made by the Hon’ble Supreme Court in the decision of AUDA - AT