Exemption U/s. 11 /12 cannot be denied by invoking Section 2(15) merely for profit from imparting of education

The assessee was a recipient of research and training grant and other income to the tune of Rs. 1.36 crores. The AO determined that the latter were commercial receipts and guided by proviso to Section 2(15) and held that the assessee could not avail the benefit under section 11(23) of the Act. The ITAT relied upon the judgement in the case of India Trade Promotion Organisation vs. Director General of Income Tax (2015) 371 ITR 333 which had observed that as long as the predominant activity of an institution is not business or commerce, and that the so called suspect income is derived on the bas...