Mere charging guarantee fees for services by trust not sufficient to invoke proviso to section 2(15)

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’

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