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2018 (11) TMI 509 - HC - Income TaxCharitable activities - exemption u/s 11 and 12 denied - Held that:- As in assessee’s own case for immediately preceding assessment years [2018 (1) TMI 189 - ITAT DELHI] held assessee is engaged in research based activity which is highly cost intensive and requires continuous spending on the innovation and new developments as it is concerning with the education of the society. The Assessee has categorically stated before the Id AO as well as before Ld CIT (A) that it is charging subscription as well as consultancy fees on actual, which fact is not denied. Therefore merely earning the surplus does not result in to the conclusion, that assessee is carrying on its activities, which can be termed as business, trade, or commerce. - Decided in favour of assessee
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