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.
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.
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