JUDGMENT

1. This appeal by the assessee filed under Section 260 a of the Income Tax act, 1961 is directed against the consolidated order dated 14.08.2020 passed by the Income Tax appellate Tribunal, 'B' Bench, Kolkata (Tribunal) in ITa Nos. 1147-48/Kol/2018 and 1608/Kol/2019 for the assessment years 2013-14 to 2015-16. The assessee has raised the following substantial questions of law for consideration:-

(i) Whether the exemption under Section 11 of the Income Tax act, 1961 can be denied on the basis of the objectives of the petitioner entity when it the same have been accepted as charitable at the time of registration under Section 12a / 12aa of the act?

(ii) Whether the activity of the petitioner of setting up of museums, science parks, planetariums, interactive galleries, exhibits and other forms of dissemination of knowledge through informal means, at the behest of other public bodies or entities, be regarded as commercial in nature and within the periphery of the proviso to Section 2(15) of the Income Tax act, 1961?

(iii) Whether the Tribunal was justified in denying the exemption under Section 11 of the act and its findings that the objects and the activities of the petitioner ar