2021 (7) TMI 936

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....doing activities which are in nature of trade, commerce or business and since the receipts from trade, commerce or business exceed the monitory limit prescribed in the proviso to section 2(15), hence exemption u/s. 11 & 12 shall not be available to the assessee. 2. On the basis of facts and circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the total addition of Rs. 6,20,24,427/- made by the AO in the assessment order. 3. The appellant craves leave to add, to alter or amend any ground of appeal raised above at the time of hearing." 2. Facts of the case are that the Quality Council of India, an Autonomous Body was set up by Ministry of Commerce & Industry, Government of India and registered as non-profits with it....

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....ued by the Assessing Officer to explain why its receipt may not be hit by proviso of section 2(15) of Income Tax Act. Section 2(15) contemplates as under: "(15) charitable purpose includes relief of the poor, education, medical relief, [preservation of environment (including watersheds, forests and wildlife) and preservation of monuments or places or objects of artistic or historic interest], and the advancement of any other object of general public utility: [Provided that the advancement of any other object of general public utility shall not be a charitable purpose, if it involves the carrying on of any activity in the nature of trade, commerce or business, or any activity of rendering any service in relation to any trade, commerce or....