Partly allowing the appeal of the Revenue the Court held that the law with regard to the interpretation of section 2(15) had undergone a change, due to the decision in Ahmedabad Urban Development Authority [2022] 449 ITR 1 (SC). As a result, the matter remitted for fresh consideration of the nature of receipts in the hands of the assessee, and the question of whether the amounts received by the assessee qualified for exemption, under section 2(15) or section 11 had to be gone into afresh. The Assessing Officer shall examine the documents and relevant papers and render fresh findings on the issue of whether the assessee was a charitable trust, entitled to exemption of its income. (AY.2010-11, 2011-12)