‘Charitable Purpose’, GPU Category- Post 2008 Amendment – Eligibility For Exemption U/S 11- Sec 2(15)- Part III

6.1    As mentioned in Part I of this write-up [BCAJ - April, 2023], history of provisions relating to exemption for charity under the Income-tax Act, right from 1922 Act to the current Act (1961 Act) and amendments made from time- to – time affecting such exemptions for Charitable Trust/institutions [Charity/Charities]; and in particular, the insertion of the proviso [the said Proviso] to section 2(15) by the Finance Act 2008 w.e.f. 1.4.2009 (2008 Amendment) placing restrictions on carrying out Commercial Activity [referred to in Para 1.6 of Part I of this write-up] has been considered by the Supreme Court in the AUDA’s case. Similarly, judicial precedents from time-to-time under the respective provisions of the Act relating to exemptions for Charity prior to 2008 Amendment have also been considered by the Supreme Court in this case as referred to in paras 4.1 and 4.2 of Part II of this write-up [BCAJ- May, 2023] 6.2    Brief facts of six categories of assessees [referred to para 2.1 of Part I of this write-up] before the Supreme Court in cases of Ahmedabad Urban Development Authority and connected matters [AUDA’s case] and the contentions raised by each one of them before the Court as well as the arguments of the Revenue are summarized in paras 3.1 to 3.3 of Part I of this write-up. 6.3    After considering the argumen