2022 (1) TMI 1376

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..... 5) charitable purpose - as per revenue assessee is involved in widespread commercial activities in nature of business and the activity of the assessee covered under the provisions of Section 2(15) of the Act and thus, exemption u/s.11 12 of the Act is not allowable to the assessee - HELD THAT:- The substantial questions of law raised are no longer res integra in view of the decision of this Court .....

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..... ribunal was justified in allowing the benefit of exemptions u/s.11 & 12 of the Act without considering the fact that the assessee is involved in widespread commercial activities in nature of business and the activity of the assessee covered under the provisions of Section 2(15) of the Act and thus, exemption u/s.11 & 12 of the Act is not allowable to the assessee?" [B] "Whether on the .....

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..... ) is applicable, the benefit u/ s.11 and 12 of the Act cannot be allowed to the assessee?" [D] "Whether on the facts and circumstances of the case and in law, the Appellate Tribunal is justified in allowing benefit of accumulation of Rs.39,88,00,000/- u/s. 11(2) without appreciating the fact that once the proviso to Section 1 & 2 to section 2(15) is applicable, the benefit u/ s.11 and .....

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