Tribunal held that Assessing Officer had erroneously treated the assessee as a mutual association instead of a charitable organisation merely on the ground that services were rendered by the assessee to its members. The assessee had not even claimed to be a mutual association and had not claimed any exemption from Income-tax on the basis of principle of mutuality. What had been claimed by the assessee was only exemption under section 11 being a charitable organisation and on fulfilment of all the conditions stipulated in sections 11 to 13 . The Department had not pointed out that the assessee’s activities were in the nature of trade, commerce or business or activity of rendering any service in relation to any trade, commerce or business and in consideration of which a cess or fee had been received by the assessee. Hence, the assessee’s case did not fall within the ambit of the proviso to section 2(15) The activities carried on by the assessee were not with a view to make profit hence entitle to exemption .  (AY.2013-14)