SLP of Revenue dismissed, the High Court  dismissed  the Department’s appeal where the  that the Tribunal had recorded findings of fact that the nature of activity of the assessee was charitable and it was not hit by the proviso to section 2(15) of the Income-tax Act, 1961 and remanded the matter to the Assessing Officer to examine the activity of the assessee and if it were found to be in consonance with the objects, allow the benefit of exemption under section 11 and adjudicate the issue of transfer of fund to infrastructure development fund in terms of the ratio laid down by the Tribunal in the cases of Saharanpur Development Authority and Khurja Development Authority.  (AY. 2012-13)