Income Tax Act Exemption Denied: Non-Member Transactions and Fee Charges Must Show Profit Motive for Section 2(15) Compliance.

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....Exemption under sections 11 & 12 denied - income derived from transactions from non-members - mere charging of fee ipso-facto would not enable an activity to be governed by the proviso to section 2(15) of the Act without establishing any profit-motive in the charging of fees. - AT....