TMI Blog2021 (10) TMI 179X X X X Extracts X X X X X X X X Extracts X X X X ..... under Section 10(23C)(vi) of the Act vide notification No.1348 dated 31st October, 2007. Though the Assessing Officer has held that the assessee-association has various source of income from commercial activities, yet this Court finds that Appellate Authorities i.e. Commissioner (Appeals) and ITAT have held that the assessee-association has not been earning any profit as the main object of the assessee-association is to improve the public transport system in the country and the road safety standards. Undoubtedly, the activities of laboratory testing and consultancy are bringing revenue to the assessee-association but the intent of such activities is not to earn profit for its shareholders/owners. Consequently, this Court is in agreement ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (1) Whether on the facts and in the circumstances of the present case and in law, the Hon'ble ITAT was correct in upholding the order of CIT (A) ignoring the fact that the activities of the assessee do not fall under any of the categories i.e. relief to poor, education, medical relief, preservation of environment and preservation of monuments or places or objects of artistic or historic interest and that the assessee had receipts under the heads Revenue from test laboratory and consultancy receipts which were commercial in nature and their aggregate value exceeded ₹ 10 Lakh? 3. Learned counsel for the appellant states that ITAT has erred in upholding the order of CIT(A) to the extent that it has overlooked that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s charitable in nature and the appellant itself has granted the assessee registration under Section 12A and also recognized under Section 10(23C)(vi) of the Act vide notification No.1348 dated 31 st October, 2007. 5. Though the Assessing Officer has held that the assessee-association has various source of income from commercial activities, yet this Court finds that Appellate Authorities i.e. Commissioner (Appeals) and ITAT have held that the assessee-association has not been earning any profit as the main object of the assessee-association is to improve the public transport system in the country and the road safety standards. Undoubtedly, the activities of laboratory testing and consultancy are bringing revenue to the assessee-associati ..... X X X X Extracts X X X X X X X X Extracts X X X X
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