TMI Blog2017 (1) TMI 616X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. - I.T.A No. 2844/Kol/2013 - - - Dated:- 14-10-2016 - Shri N. V. Vasudevan, JM And Shri M. Balaganesh, AM For the Appellant : Shri Rajat Kr. Kureel, JCIT, Sr. DR For the Respondent : Shri Miraj D. Shah, AR ORDER Per Shri M. Balaganesh, AM This appeal by revenue is ar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7,28,088/- 12,66,58,784/- 3.1. The income of the society includes dividend, interest, voluntary contributions, rent, etc. The income of the school and colleges include tuition fees, development fees and other fees. From the books of accounts produced for each unit which were also subjected to verification on test check basis by the ld AO, the ld AO observed that assessee had incurred substantial expenditures in different heads under the normal academic curriculum of the schools and colleges. The ld AO observed that the following expenses incurred by the assessee society shall not be regarded as application of income as according to him the same are not relevant for the purpose of objects of running an educational society :- (a) Tour expenses Foreign tour provided to students of Bhowanipur Gujarati Education Society College (b) Functions and Festivals Annual Fashion Show and Mr. and Mrs University expenses. 3.2. The assessee replied before the ld AO as below:- The management has always felt that seeing is believing and has been the first among the Educational Institutes to undertake foreign tours for the benefits of the stu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... artment of the college holds annual fashion show with a view to providing a platform to their students to display what they have learnt. Such platform helps the student in development of skill as well serves as a platform for meeting of students and the industry which ultimately helps in employment of the students. 6. Aggrieved, the revenue is in appeal before us on the following grounds:- 1. The Ld. CIT (A) - XIV, Kolkata has erred in deleting the disallowance of ₹ 29,43,011/- claimed on account of foreign tours debited under the head of Tour Expenses, overlooking the fact that 125 students were taken on foreign tour through a tour operator 'Club 7' for entertainment, thereby allowing assessee's unacceptable claim that the foreign tour was organised in course of imparting education. 2. The Ld. CIT (A)-XIV, Kolkata has erred in deleting the disallowance of ₹ 36,53,054/- claimed on account of a fashion show debited under the head of Function Festival A/c, ignoring the fact that the fashion show was organised in college had participation from students unconnected with the vocational course in fashion designing, thereby be lying the assessee' ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 37,03,218 23,32,705 2010-11 59,08,897 48,58,897 7.1. With regard to the tour expenses incurred by the assessee , we hold that the aforesaid tour expenses incurred on students becomes an integral part of learning and enables an opportunity for the students to gain hands on experience from such trips by imbibing different cultural values , language, literature of different countries, which would be part and parcel of the vocational art academy course run by the assessee society. These tours would also enable the students to understand the history of different countries which would definitely fall under the category of imparting education. Moreover, these type of tours would also provide greater close bonding between the students and the teachers which in turn would increase the confidence of the students to interact with the teachers thereby improving the communication and interactive skills of the students. We find that the ld CITA observed that the 2015 Secondary Curriculum issued by the Central Board of Secondary Education , New Delhi oat page 234 had suggested essential activit ..... X X X X Extracts X X X X X X X X Extracts X X X X
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