2022 (11) TMI 584 - AT - Income Tax
Benefit of exemption u/s 11/12 - Denial of claim activities of the assessee are commercial in nature and covered by 1st proviso to section 2(15) - HELD THAT:- We find that on identical facts for the A.Y. 2011-12, in assessee’s own case[2018 (7) TMI 1478 - ITAT DELHI] there was no material which may suggest that the assessee association was conducting its affairs solely on commercial lines with the motive to earn profit. There is also no material which could suggest that the assessee association has deviated from its objects which it has been pursuing since past many decades. In our humble opinion and understanding of law, proviso to section 2(15) of the Act is not applicable to the facts of the case and the assessee-association deserves benefit u/s 11/12 - Appeal of the Revenue is dismissed.