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    <title>2026 (5) TMI 1394 - ITAT DELHI</title>
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    <description>A statutory development authority engaged in planned development and public welfare was treated as not carrying on commercial activity merely because it undertook development functions or earned receipts from those functions. Applying binding precedent from the assessee&#039;s earlier years and coordinate bench decisions, the tribunal held that the proviso to section 2(15) was not attracted and the exemption under section 11 remained available. The principle of consistency also supported the result, as no materially different facts were shown for the year under consideration. The issue was therefore decided in favour of the assessee and against the Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792192</link>
      <description>A statutory development authority engaged in planned development and public welfare was treated as not carrying on commercial activity merely because it undertook development functions or earned receipts from those functions. Applying binding precedent from the assessee&#039;s earlier years and coordinate bench decisions, the tribunal held that the proviso to section 2(15) was not attracted and the exemption under section 11 remained available. The principle of consistency also supported the result, as no materially different facts were shown for the year under consideration. The issue was therefore decided in favour of the assessee and against the Revenue.</description>
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