Assessee is  a non-profit organization, which is  engaged in promoting export of leather industries. It is  facilitating participation of its members in trade fairs and had claimed exemption under section 10(23C)(iv). Assessing Officer denied  the exemption. CIT(A) affirmed the order of the AO. On appeal the Tribunal held that   Apex Court in case of Asstt. CIT (E) v. Ahmedabad Urban Development Authority (2022) 449 ITR 1 /(2023) 291 Taxman 11(SC)  held that while actually carrying out objectives of general public utility (GPU), if some profit is generated, it can be granted exemption provided quantitative limit of not exceeding 20 per cent under second proviso to section 2(15) for receipts from such profits, is adhered to. On facts  since net surplus of Rs. 7.62 crores was less than 20 per cent of total receipts of assessee exemption under section 10(23C)(iv) could not be rejected under second proviso to section 2(15). (AY. 2016-17)