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ITAT allowed the appeal of the assessee and quashed the revisionary order passed under s.263, holding the claim of exemption under ss.11/12 sustainable. The Tribunal held the assessee's activities fall within "advancement of any other objects of general public utility" under s.2(15) and noted s.12AA registration remains in force. A Coordinate Bench decision in the assessee's own case was binding and not stayed; hence the ITO was bound to follow it. Applying the Supreme Court's interpretation of the proviso to s.2(15), the Tribunal found no trade/business or rendering-of-service nexus and receipts did not breach the 20% threshold. Invocation of Explanation 2 to s.263 was held unjustified.
ITAT allowed the appeal of the assessee and quashed the revisionary order passed under s.263, holding the claim of exemption under ss.11/12 sustainable. The Tribunal held the assessee's activities fall within "advancement of any other objects of general public utility" under s.2(15) and noted s.12AA registration remains in force. A Coordinate Bench decision in the assessee's own case was binding and not stayed; hence the ITO was bound to follow it. Applying the Supreme Court's interpretation of the proviso to s.2(15), the Tribunal found no trade/business or rendering-of-service nexus and receipts did not breach the 20% threshold. Invocation of Explanation 2 to s.263 was held unjustified.
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