Media Research Users Council v. ACIT [2024] 205 ITD 170 (Mum)(Trib)

S. 2(15) : Charitable purpose-General public utility-Publishing newspapers -Receipts more than 10 lakhs -Matter remanded for verification. [S. 11, 12A]

Tribunal held that the Revenue without examining whether activities were in nature of trade commerce of business denial of exemption is under section 11 is not justified merely on the ground that receipts had exceeded the limit of Rs.10 lakhs. The matter is remanded to the Assessing Officer to decide the issue in accordance with the judgement of apex court in Ahmedabad Urban Development Authority (2023) 449 ITR 1 (SC), examine the status of charitable entity granted under section 12A of the Act, examine the plea that the assessee has very nominal profit or margin from the main activity of selling IRS reports to members and non -members and also to decide the issue on principle of mutuality in light of the decision earlier years order of the Tribunal. (AY. 2009-10 to 2013-14)