The ITAT allowed the assessee-society's appeal and restored...

The ITAT allowed the assessee-society's appeal and restored exemption u/s 11 and 12. It held that the assessee, registered u/s 12A and under the relevant Charitable Societies Act, is predominantly engaged in "relief of the poor" u/s 2(15), focusing on upliftment and economic support of small and marginal farmers. The Tribunal found that large-scale milk procurement, processing and sale are incidental and inseparable from its charitable objects, aimed at ensuring remunerative prices and preventing exploitation by middlemen, with separate books maintained as required u/s 11(4A). The AO's characterization of these activities as purely commercial and consequent denial of exemption was held to be unsustainable, and the additions were directed to be deleted.