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    <title>2025 (8) TMI 1501 - ITAT BANGALORE</title>
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    <description>A statutory urban development authority&#039;s development and sale of sites were treated as incidental to its public utility object, so the proviso to section 2(15) and section 13(8) did not apply to deny exemption under section 11. The controlling test was the predominant charitable purpose, not the presence of surplus or incidental receipts. On that basis, the accompanying additions and disallowances, including prior period expenses, assets written off, deposits, cess liabilities, rent recoverable, and delayed service tax interest, were not sustained where they were either already dealt with on facts or became untenable once section 11 exemption was upheld.</description>
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      <description>A statutory urban development authority&#039;s development and sale of sites were treated as incidental to its public utility object, so the proviso to section 2(15) and section 13(8) did not apply to deny exemption under section 11. The controlling test was the predominant charitable purpose, not the presence of surplus or incidental receipts. On that basis, the accompanying additions and disallowances, including prior period expenses, assets written off, deposits, cess liabilities, rent recoverable, and delayed service tax interest, were not sustained where they were either already dealt with on facts or became untenable once section 11 exemption was upheld.</description>
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