TMI Blog2020 (4) TMI 614X X X X Extracts X X X X X X X X Extracts X X X X ..... tudents for value education workshop and giving coaching for the sports. Such an activity ostensibly falls within the ambit of category of education and giving coaching in sports is also one of the related activities for the overall development of the youth and the sports activities. Any fees received from such activities cannot be held to be in the nature of any trade, commerce, business activities. In this case, proviso to section 2(15) may not attract in this case, because said proviso is applicable only where a trust is carrying out advancement of any other object of general public utility and here the activities of the assessee trust falls in the realm of activities of educational and sports. Accordingly, we hold that assessee i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iness/commerce activities and first proviso to section 2(15) of the Act is invoked in the case of the assessee. The AO denied benefit of section 11 12 to the assessee and completed the assessment at ₹ 74,74,420/-. 3. Assessee challenged the addition before Ld. CIT(A) and submitted that assessee is registered u/s 12AA(1) of the Act on 29.11.2006. The main object of the assessee is to promote the education in sports and other allied education activities. The assessee has not conducted any trade, commerce or business and relied upon the certain decisions in support of the contention. The Ld. CIT(A) accepted the contention of the assessee and directed the AO to allow exemption u/s 11(1) of the Act. 4. Ld. DR relied upon the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h of the Institution and the child. b) Educational trends in the nature of Academic, Cultural, Arts and Sports, strategic environments through National academic institutions and school for cohesive growth of the child. c) Work and organize academic conferences, workshops, projects and youth camps with training courses for qualitative growth of the faculty with the child at the centre. 6. The nature of receipts as shown in the income and expenditure account and has also been noted by the Ld. AO is flowing from the activities carried out in pursuance of the objects for which it was granted registration u/s 12AA. Assessee trust has basically has received fees from the students for value education workshop and giving coaching fo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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