Court Rules Assessee's Activities Don't Qualify for Exemption u/s 11; Misinterpretation of Section 2(15) Proviso Noted.

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....Exemption u/s 11 - Charitable activity u/s 2(15) - The general public utility from such construction is derived as fact with the facilities constructed by the assessee are put to utility. The activity undertaken by the assessee on one hand and on another hand with the ultimate purpose or user of buildings constructed by the Government shall not be mistaken with one another. The assessee is interpreting proviso by excluding one of the important limbs, viz. involves the carrying on of any activity in the nature of trade, commerce or business. The decision of the authorities are independently considered and by taking note of CBDT Circular and above reasoning, we are of the view that the substantial question raised could be answered in favour of the revenue and against the assessee. - HC....