Proviso to Section 2(15) requires fresh scrutiny where charitable activity must be tested against fee-based service exclusions.

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....The ITAT remitted the question whether the proviso to Section 2(15) applied to the assessee's activities, holding that the CIT(E) had not properly applied the Supreme Court's ratio in ACIT v. Ahmedabad Urban Development Authority. It directed fresh adjudication on whether the assessee's consumer grievance, workshops, research, regulatory reporting and outreach activities fell within the exclusion for services in relation to trade, commerce or business for fee or other consideration, or remained advancement of general public utility. Because the cancellation of registration under Section 12AB and the consequential refusal of approval under Section 80G depended on that issue, both were also remanded for fresh decision.....