TMI Blog2009 (12) TMI 1016X X X X Extracts X X X X X X X X Extracts X X X X ..... e Act with the main activity to promote the game of Golf in India. In the return filed for the year under consideration, the assessee had declared casual membership fees. The assessee was asked to furnish list of casual members and the fees charged from them and details of services enjoyed by them. Vide letter dated 19.11.2008, the assessee has furnished full details of casual members, fees charged from them alongwith services enjoyed by them and receipts from the same. The assessee also filed fee structure of the casual members. The AO observed that fees charged from the casual members was much higher than the permanent members and the casual members are not eligible for other facilities. The AO observed that casual members did not e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g separate books of account regarding this business activity. As per AO, it was a business income and not income of the mutual interest that was not liable for exemption u/s 11. There is no merit in the AO s action for treating the fees received from the casual members as business income. The assessee club was maintaining required records with regard to income and expenditure. There is no requirement of maintaining separate accounts with respect to the fees received from different kinds of members as provided in the article of association. The assessee, Delhi Golf Club Limited, is a well-known club having been in Delhi for over five decades. Its main object is to promote the game of golf in India. It has members from various walks of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... son. It is sufficient if it reaches a sizeable number of members of the public. (2) To serve a charitable purpose object should be to benefit the mankind and not the whole of mankind in a particular country or province. (3) The section of public which is expected to benefit should be well defined even though it does represent only a portion of the mankind. (4) The intention of providing the benefit to portion of the public as individual should be clearly spelled out. 6. The question whether promotion of sports and games can be considered as being a charitable purpose has been examined. The Board are advised that the advancement of any object beneficial to the public or a section of the public as distinguished from an individua ..... X X X X Extracts X X X X X X X X Extracts X X X X
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