AGRA DEVELOPMENT AUTHORITY,AGRA vs. DCIT., CIRCLE-1, AGRA

The appeals of the assessee are allowed and the appeal of the revenue is dismissed

138 succinctly held vide para 19 as follows:-"The final and determining factors, it was observed was consequential profit motive or purpose behind the activity and when an activity is trade, commerce or business was elucidated in Institute of Chartered Accountants of India (2012) 347 ITR-99(Delhi) in the following words: 'Section 2(15) defines the term charitable purpose

VISHWAMBHAR DAYAL AGARWAL,AGRA vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE2(1)(1), AGRA, AGRA

In the result, the appeal filed by the assessee is allowed, the CO raised by the assessee and appeal filed by the Revenue are dismissed