https://www.taxtmi.com/caselaws?id=190690 The proviso to Section 2(15) of the Income-tax Act, 1961 does not deny Section 11 exemption where the assessee's predominant activity is not business or commerce, and incidental income arises only from subsidiary activities. The text notes that research and training grants, along with other receipts, were treated by the Assessing Officer as commercial income, but the Tribunal applied the established principle that exemption cannot be refused merely because some income is earned incidentally. That approach is said to have been affirmed in earlier decisions, and the proviso was not applied to withdraw the Section 11 benefit. en-us Fri, 25 Nov 2016 00:00:00 +0530 Wed, 22 Feb 2017 12:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190690 The proviso to Section 2(15) of the Income-tax Act, 1961 does not deny Section 11 exemption where the assessee's predominant activity is not business or commerce, and incidental income arises only from subsidiary activities. The text notes that research and training grants, along with other receipts, were treated by the Assessing Officer as commercial income, but the Tribunal applied the established principle that exemption cannot be refused merely because some income is earned incidentally. That approach is said to have been affirmed in earlier decisions, and the proviso was not applied to withdraw the Section 11 benefit. Case-Laws Income Tax Fri, 25 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190690