In the result, the appeals of the assessee are partly allowed whereas the Cross Objections of the Revenue are partly allowed for statistical purposes
Bench: Shri A. D. Jain & Shri T. S. Kapoor
68. CIT (E) has attempted to equate these ''IDAs' with private builders and developers. Para-11 of said order is reproduced as under:- "The law requires a conjunctive test whereby objects have to be charitable and genuineness of charitable activities should be established for registration of application u/s 12A. Mere recital of objects or activities without cogent or corroborative evidence