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In favour of assessee.The mere fact that certain fee was charged by the assessee while rendering certain services and surplus was generated, the said fact alone, would not disentitle the assessee to claim the impugned exemption u/s 11 & 12 considering the fact that the primary objects of the assessee were charitable in nature.

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Sec. 11 & 12 of Income Tax Act, 1961— Exemption — Assessee entitled for exemption u/s 11 & 12 and the mere fact that certain fee was charged by the assessee while rendering certain services and surplus was generated, the said fact alone, would not disentitle the assessee to claim the impugned exemption u/s 11 & 12 considering the fact that the primary objects of the assessee were charitable in nature - NATIONAL PAYMENTS CORPORATION OF INDIA V/s DEPUTY CIT - [2020] 27 ITCD Online 023 (ITAT-MUMBAI)