Assessee's Circulation Audit Not Commercial; Exemption u/s 11 Allowed Despite AO's Business Activity Claim.

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....Exemption under section 11 - As per AO assesseee’s activity of conducting circulation audit was clearly a business activity for which consideration in the form of membership subscription and one time entrance fees was received - Merely came into existence of provision of Section 2(25) of the Act nowhere makes the object of the Assessee commercial in nature. Instances of business and profession are also not on record. Taking into account all the facts and circumstances of the case, we are of the view that the CIT(A) has wrongly denied the claim of the assessee u/s 11 of the Act which is liable to be allowed in the interest of justice. - AT....