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

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

property held under trust or from voluntary contributions and to ascertain whether in the case of the assessee the character of income falls under any one of the two categories envisaged in Sections 11(1)(a), (b), (c), and (d), the factual activities being carried out by the assessee is to be examined. The assessee is engaged in the activity