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of Denial of exemption u/s 10(46) was incorrect - petitioner was not systematically indulging in commercial activities with profit motive - loans extended were not for commercial purposes but to fulfil developmental objectives - investments in bonds, shares, and fixed deposits had direct connection with assigned role under UPID Act - petitioner acts as agent of Government for planned development, not a profit-oriented corporation - extending loans was directed by State Government, not motivated by profit intent - financial statements show negative income-expenditure margin, negating commercial assumption - HC quashed order, directed processing of exemption application u/s 10(46) in light of observations.
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