The  objects/activities of the trust is  improvement in the town of Sangrur . The Assessing Officer  held that the activities of the trust with regard to the acquisition of land and development of the land and sale thereof cannot be treated as charitable activities under ‘general public utility. The Assessing Officer  held that  the Assessee was covered by the proviso to section 2(15) of the  Act and could not be held to be engaged in charitable activities  therefore, the Assessee was not liable for exemption u/ss 11 and 12 of the I.T. Act, read with  the provisions of section 13(8) of the Act .During the year, the Assessee had incurred a loss, i.e., excess expenditure over income. The Assessing Officer  assessed the income at nil .  The CIT(A)  up held the order of the Assessing Officer . On appeal the Tribunal held that  where the plots and premises are sold at market price, the activity is not a commercial or business venture. It is sufficient if the trust does precisely what the last category in section 2(15) states, that is, being involved in activities for the advancement of an object of general public utility; that these activities, which are undertaken by the assessee by virtue of the Punjab Town Improvement Act, 1922, include a proper systematic development of certain areas. Therefore, regulatory activity, necessitating fee or cess collection in terms of enacted law, or collection of amounts in furtherance of activities such as education, regulation of the profession, etc., are per se not business or commercial in nature. Statutory boards and authorities, who are under mandate to develop housing, industrial and other estates, including the development of residential housing at reasonable or subsidised costs, which might entail charging higher amounts from some section of the beneficiaries, to cross-subsidize the main activity, cannot be characterised as engaging in business. Accordingly  allowed the exemption under section 11 of the Act . (ITA No. 273 / Chd/ 2020 dt . 25-5 -2023 ( AY. 2016 -17