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of The ITAT allowed the appellant's appeal for statistical purposes and remitted the matter to the CIT(E) with directions to admit and consider the additional evidence after affording the appellant an opportunity of hearing and decide the question of registration under s.12AA and allegations under s.13(1)(c) in accordance with law. The Tribunal held that the trust's objects could constitute benefit to the public (a cross-section) rather than to only its members, rejected the characterisation of the activities as inherently commercial given minimal volume, no fees and use of institutional infrastructure, and found that conclusions of non-genuineness were not warranted on the record.
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