Section 2(15), 12A and 80G of the Income-tax Act, 1961—Charitable purpose—The activities of the Assessee can in no way be termed as trade and commerce etc. as it is not charging any fee from the beneficiaries who belong to the poor communities and the NGOs like the WHO, UNICEF etc. which have engaged the Assessee are themselves charitable instructions and they ensure that the grants given to the Assessee are utilized for the purpose of charitable activities and not for any business and consultants' fees were also paid out of such grants and further, the Revenue was not able to show that any part of the profit or gains has been transferred to any member of the Assessee society, thus, activities of the Assessee would fall within the scope of 'general public utility' under Section 2 (15) and the Assessee is therefore entitled to exemption under Sections 11 and 12 - CIT V/s PRAXIS INSTITUTE FOR PARTICIPATORY PRACTICES - [2018] 1 ITCD Online 359 (DEL)