The assessee, a statutory Town Planning Authority under the Karnataka Town and Country Planning Act, 1961, undertook public welfare and development activities. The AO denied exemption u/ss. 11 and 12 holding that activities were commercial in nature under the proviso to section 2(15). The Tribunal held that the assessee was functioning under strict Government control, its accounts were audited by Government, its budget was approved by the State and any surplus or assets reverted to the State upon dissolution. These facts showed that the activities were not profit-motivated but for public utility. Held, exemption u/ss. 11 and 12 allowable, proviso to section 2(15) not attracted.  (AY. 2012-13, 2013-14, 2015-16, 2018-19)