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TMI Blog2022 (7) TMI 1235X X X X Extracts X X X X X X X X Extracts X X X X ..... Per George George K , JM : These appeals at the instance of the Revenue are directed against five orders of the CIT(A), all dated 23.03.2022. The relevant assessment years are 2012-2013 to 2015-2016 and 2017-2018. 2. Common issue is raised in these appeals, hence, they were heard together and are being disposed of by this consolidated order. Identical grounds are raised, they read as follows:- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... resulted in huge surplus year after year thereby rendering the activities of the assessee commercial in nature. 4. Whether on the facts and in the circumstances of the case and in law, the CIT(A), NAFC, is right in allowing the claim of exemption of the assessee u/s 11 without appreciating the fact that the activities of the assessee are in the nature of trade, commerce or business and therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... u/s 11 of the I.T.Act (in respect of income derived to the assessee which falls under the last limb of definition of charitable purpose u/s 2(15) of the I.T.Act). The A.O. in taking the above view had also held that the ITAT's order in the case of Bangalore Development Authority in ITA Nos.1968 to 1971/Bang/2018 (order dated 04.06.2019) has not been accepted by the department and further appeal u/ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n the ambit of proviso to section 2(15) of the I.T.Act. 5. Aggrieved by the orders of the CIT(A), the Revenue has filed these appeals for assessment years 2012-2013 to 2015- 2016 and 2017-2018. The learned Departmental Representative relied on the assessment orders and the grounds raised. 6. None was present on behalf of the assessee. 7. We have heard the learned DR and perused the material on ..... X X X X Extracts X X X X X X X X Extracts X X X X
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