https://www.taxtmi.com/caselaws?id=201896 Whether petitioners were entitled to a s.197(1) certificate for non-deduction given their charitable-status exemptions under ss.11/12A, in light of the amendment to s.2(15) effective 1.4.2009: Court held that the assessee's activities-acquisition, construction, infrastructure development and letting of premises on a business-oriented basis-fall within the fourth limb of amended s.2(15) prohibiting activities "in the nature of trade, commerce or business" notwithstanding governmental connection; the commercial character evidenced by income schedules and business-style deductions (including depreciation) defeats charitable exemption. Consequence: refusal to issue s.197(1) certificates was lawful and the writ petitions were dismissed. en-us Fri, 16 Oct 2009 00:00:00 +0530 Wed, 14 Jan 2026 14:40:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=201896 Whether petitioners were entitled to a s.197(1) certificate for non-deduction given their charitable-status exemptions under ss.11/12A, in light of the amendment to s.2(15) effective 1.4.2009: Court held that the assessee's activities-acquisition, construction, infrastructure development and letting of premises on a business-oriented basis-fall within the fourth limb of amended s.2(15) prohibiting activities "in the nature of trade, commerce or business" notwithstanding governmental connection; the commercial character evidenced by income schedules and business-style deductions (including depreciation) defeats charitable exemption. Consequence: refusal to issue s.197(1) certificates was lawful and the writ petitions were dismissed. Case-Laws Income Tax Fri, 16 Oct 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=201896