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2021 (5) TMI 745 - AT - Income TaxExemption u/s 11 - charitable activity u/s 2(15) - HELD THAT:- Assessee is not carrying out of any activity which is related to advancement of any other object of general public utility. Source of the income of the assessee is from the member’s fee and from the organization of exhibitions etc which is done only to promote the interest of the members. The assessee filed the memorandum of association and also referred to various objects of the assessee which has been reproduced above and we find that none of the objects of the assessee can be construed as advancement of any other object of public utility. The case of the assessee finds from the decision of Society of Indian Automobile Manufacturers [2016 (6) TMI 802 - ITAT DELHI] wherein it is held that if the purpose of all the activities is to promote objects for which it was set up, then it will not be caught within sweep of proviso notwithstanding fact that they result in some income from carrying out such activity. We direct the AO to allow the exemption under section 11 of the Income Tax Act of the assessee and further hold that the case of the assessee does not fall within ambit of the proviso to section 2(15) of the Act. The appeal of the assessee is allowed.
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