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- Clubs: A restricted category of professions, clubs, co-operatives and even Gurukuls may qualify for exemption if, in simple ventures, substantially and going by the dominant nature criterion substantively, no employees are entertained, but in minimal matters marginal employees are hired without destroying the non-employee character of the unit. But larger clubs are “industry” as per Bangalore Water Supply case.
- Universities, Research Institutions: As regards institutions, if the triple tests of systematic activity, cooperation between employer and employee and production of goods and services were to be applied, a university, a college, a research institute or teaching institution will be “industry”.
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