Terms "any trade, commerce or business" occurring u/s 2(15) refer to trade, commerce or business pursued by recipient to whom service is rendered

RELEVANT PARAGRAPH

14. From the nature of activities being pursued by the petitioners, particularly as contained in the ‘memorandum of association’ extracted by the respondent in the statement filed in WP(C) 6899/2009 (stated as more or Jess similar in the other case as well), it is very much evident that the derivation of income by the petitioner cannot be held as merely the income from property, so as to oust the involvement of ‘trade, commer

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