TMI Blog2004 (7) TMI 44X X X X Extracts X X X X X X X X Extracts X X X X ..... re sold in pots and also develops seeds, garden implements, manure, etc. by engaging 54 employees - If that be so, the respondent has to receive a minimum sale consideration for giving payment to the employees and such act of the respondent/assessee-society by itself, in our considered opinion, cannot be construed as commercial in nature. Similarly the reason that they have not conducted flower sh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tled for the exemption under sections 11 to 13 of the Income-tax Act. The issue is relating to the assessment year 2000-2001. The assessee is a society claiming the status as association of persons, who are engaged in the business of purchase and sale of agri-horticultural products like manure, seeds, garden implements, flower pots, etc. having engaged more than 259 members and 54 employees. The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e-tax (Appeals), Chennai on October 23, 2002. However, the further appeal by the respondent/assessee before the Tribunal was allowed in favour of the assessee by an order dated June 26, 2003. Hence, the Revenue has filed the above appeal on the following substantial question of law: "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was right in holdin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot conducted flower show for the past ten years has not changed the character of the charitable object of the society as defined under section 2(15) of the Income-tax Act, which reads as follows: "2.(15) 'charitable purpose' includes relief of the poor, education, medical relief, and the advancement of any other object of general public utility." It is trite law that inclusive definition widen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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