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Mere charging guarantee fees for services by trust not sufficient to invoke proviso to section 2(15)
Case Law Details
- Case Name
- Credit Guarantee Fund Trust For Micro And Small Enterprises Vs ITO (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2018-19
- Courts
- All ITAT, ITAT Mumbai
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Credit Guarantee Fund Trust For Micro And Small Enterprises Vs ITO (ITAT Mumbai)
ITAT Mumbai held that mere charging of guarantee fees for services by the assessee trust ipso facto is not sufficient to invoke the proviso to section 2(15) of the Income Tax Act, that too without establishing that the object and purpose of the assessee is profit motive.
Facts-
The assessee trust is a irrevokable trust settled on 27.07.2000 by the Hon’ble President of India acting through the Ministry of Small Scale Industry (SSI) & Average Rate Index (ARI), Government of India and Small...






