advanced by the Ld. DR that micro financing
activity is merely a money lending activity without any charitable object
cannot be accepted. There is nothing ... activity carried on by the assessee is of
microfinance activity with the predominant intention of making profit and no
activity other than microfinance activity
between running the primary activity for profit and having
incidental profit-making activities. In assessee's case, micro finance is the primary
activity under ... primary activity on commercial principles with profit
intent. The incidental activity may generate income and feed the primary activity
but if the primary activity
retention, of the income
from such activity. He, therefore held that the activity of micro
finance squarely falls under the definition of trade, commerce ... micro financing constituted charitable activity.
15. The assessee explained before us that in the activity of
micro financing, the assessee obtained loan from banks
though
admitting that the micro finance Activity is Charitable activity in the
advancement of GPU and erroneously concluded that the appellant ... question arises as to whether the activities of promoting
micro finance services, as permitted from time to time by the Reserve
Bank of India, exclusively
though
admitting that the micro finance Activity is Charitable activity in the
advancement of GPU and erroneously concluded that the appellant ... question arises as to whether the activities of promoting
micro finance services, as permitted from time to time by the Reserve
Bank of India, exclusively
incidental activities must be from the
principal activities themselves. There cannot be one source for the
principal activities and another source for incidental activities ... hinges on the nature of micro financing activity of the
appellant. Insurance activity being a corollary of the micro
finance activity, whatever holds true
development activity and not a
business activity of the orgnisation at any means. The additional surplus created out
of this activity is activity is again ... micro-credit activities can be
considered to be activities that target the objective "relief of the poor"
ii) Whether the micro-finance
above order would show that the Tribunal has
held micro financing activity charitable in nature in the facts of the
case for following reasons ... activities. Without examining the activities being carried out by the
assessee it would be pre-mature to hold that the micro financing
case of Disha India Micro Credit Vs. CIT wherein the
Tribunal elaborately dealt with the activity relating to micro finance and came to
the conclusion ... incidental activities must
be from the principal activities themselves. There cannot be one source for the
principal activities and another source for incidental activities
involved therein. Merely, because
there was a surplus from the activity of micro financing, that by itself could not be a
ground to say that ... Thus, mere because there was a surplus from the activity
of micro financing, that by itself, cannot be a ground to say that the assessee
