Assessee, established as a charitable company under Section 8 of Companies Act and registered under Section 12A, aimed to set up a research centre for organic farming, promote skill development, and engage in domestic and international agro-product trade. Assessing Officer held that assessee’s activities were primarily business-oriented with a profit motive, and charitable aspects were merely incidental hence denied the exemption under section 11 of the Act. First appellate Authority and Tribunal affirmed the order of the Assessing Officer. On appeal the Court held that  the assessee procured agricultural produce from poor and marginal farmers, prevented exploitation by middlemen, and provided assistance through crop saplings and awareness programs and it’s business activities, including buying, selling, and trading agro-products, were incidental to its main objectives of establishing a research centre in organic farming. Court also held that the Authorities overlooked evidence that a significant portion of income was given to poor farmers, which, if considered, would have shown that assessee’s activities were primarily aimed at providing relief to poor, aligning with its charitable objectives. Accodingly the exemption claimed by the assessee is up held and order of the Tribunal is set aside. (AY. 2017-18 & 2018-19)