Nirmithi Kendra was a charitable society promoted by Government of Kerala for serving as seminal agency to generate and propagate innovative housing ideas, production and distribution of innovative building materials, etc. During current year, assessee undertook construction activities under State PWD department such as Panchayath Community Hall, Kudumbasree womens hostel, Krishibhavan office, Vayanasala Office etc. in lieu of 2.5 per cent supervision charges . AO denied the exemption on the ground that  construction activity carried on by assessee was  a business activity . On appeal the Tribunal held that since such activity became principal activity and no more incidental activity, and the assessee had itself carried on a business which was not at all property held under trust, provisions of S. 11(4A) would be applicable,  hence denial  exemption  is held to be justified. (AY.2009-10, 2013-14)