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2017 (1) TMI 616 - AT - Income TaxExemption u/s 11 - Treatment to tour expenses and fashion show expenses - assessee is a charitable society registered u/s 12A - Held that:- We find that there is no material brought on record by the ld AO to suggest discrimination of the students who get selected to participate in the tour. In view of these findings, we have no hesitation in holding that the incurrence of tour expenses would definitely form part of the application of income of the assessee society and is part and parcel of the activity of imparting education. It is not in dispute that the vocational training department of the assessee society conducts annual fashion shows and Mr & Mrs University competition. We hold that these shows admittedly provides a platform for the students to display their talents and also to exhibit what they had learnt in the classroom. This also creates lot of employment opportunities for the students. We hold that these events help in students shedding their inhibitions and come out of stage fear which in turn enables the students to meet the society at large with greater confidence. This is similar to institutes like National Institute of Fashion Technology set up by Government of India who are also holding fashion shows for similar purposes, as rightly pointed out by the ld CITA. We hold that this also forms an integral part of education, learning and training of students. We find that the ld AO treated these expenditures to be in the nature of advertisement for the institution, which in turn would again have to be construed as application of income in pursuance of the objects of the assessee society. Hence in any case, this would only fall under the ambit of application of income. Thus we hold that both the tour expenses and fashion show and Mr & Mrs University expenses incurred by the assessee society would have to be construed as application of income in pursuance of objects of the assessee society. - Decided in favour of assessee.
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