In the result, appeal of the assessee is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniaarambh Foundation Cit-(Exemption) 220 Saket Nagar Bhopal Saket Nagar Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aabaa 0609F Assessee By Shri Kunal Agrawal Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 12.12.2023 Date Of Pronouncement 04.01.2024

section 2(15) is not applicable in the case of the assesse. Even otherwise the proviso can be invoked only when the activities of the assessee are in the nature of advancing general public utility and that itself would not lead to the conclusion that the assessee is engaged in any trade commerce or business or provide services in relation