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The activities under taken by the present assessee like Light and Sound Show, present Security Service Charges for pre serving and maintaining/up-gradation and maintenance of Krishna Museum expenditure of celebration of Geeta JayantI etc. are all relatable activities commensurate with it saims and objects involving no activity in the nature of trade, commerce or business.

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Sec. 11 of Income Tax Act, 1961 - Charitable Purpose – Revenue filed appeal against the order of CIT(A) stating that the CIT(A) committed erred in deleting the addition amounting to Rs. 4,93,67,440/-ignoring the fact that the receipts of the assessee like interest, rent receipt and lease receipt of commercial land are not charitable in nature and also the expenses of the assessee like light and sound show security service charges, upgradation of Sh. Krishna Museum, expenditure on celebration of Geeta Jyanti, land compensation etc. are not charitable in nature and the activities of the assessee do not get covered under section 2(15) of the Act,1961. The assessee is engaged in maintaining and preserving the historical places in and around 48 kms of Kurukshetra and providing facilities for tourists/pilgrims including celebration for Geeta Jayanti at Bharam Sarovar and maintaining of Krishna Museum at Kurukshetra etc. as per the aims and object of the Trust were carried out. ITAT dismissed the appeal of the revenue holding that:- In the absence of any fact, instance or example on record to show that the activities of the assessee-trust are commercial ventures, we find no good reason to vary the conclusion drawn.—Jt. CIT vs. KURUKSHETRA DEVELOPMENT BOARD.[2020] 79 ITR (TRIB) 031 (ITAT-CHANDIGARH)

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