Assessee-society, registered under section 12A, which is  engaged in arrangement, management and enhancement of immovable property in order to earn rent, to earn profit after sell, to earn donation etc.-It had claimed exemption under section 11 in respect of its rental income. Assessing Officer,  rejected assessee’s claim of exemption under section 11 holding that assessee-society was advancing object of general public utility and rent receipt from such activity was more than prescribed limit of Rs. 25 lakhs, therefore, activities of assessee were not for charitable purpose. Commissioner (Appeals) allowed benefit of exemption under sections 11 and 12 to assessee. On appeal the Tribunal held that   there was no material brought on record to support fact that assessee was acting with profit motive so far in activities carried out. Receipt that assessee received was invested or expended for object of society and Assessing Officer failed to bring on record as to why rental income was treated as commercial income.  Since receipt from rent was in course of actual carrying out of objects of general public utility and same was below 20 per cent, Commissioner (Appeals) is  justified in allowing benefit under sections 11 and 12 to assessee.  Tribunal also held that  since copies of receipts contained direction of donor that money were for construction of fixed assets i.e. bhawans only and assessee had done that activity, Commissioner (Appeals) was justified in allowing benefit of section 11 to assessee. (AY. 2016-17)