Exemption for application of income outside India upheld where sports promotion objects covered overseas event participation.

The Delhi High Court found no substantial question of law in the Revenue's challenge to the Tribunal's affirmation of exemption under section 11(1)(c) for expenditure applied outside India. It accepted the Tribunal's view that the assessee's objects and activities were directed towards promoting sports persons in the Ministry of Railways, and that participation in sports events outside India fell within the disputed application of income. As no legal infirmity or error warranting interference was shown in the impugned order, the Revenue's appeal failed.

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Issues: Whether the Revenue's appeal raised any substantial question of law against the Tribunal's affirmation of the exemption-related finding under section 11(1)(c) concerning expenditure applied for purposes outside India.

Analysis: The Court found no legal infirmity in the Tribunal's order upholding the appellate finding that the assessee's objects and activities were directed towards promoting sports persons in the Ministry of Railways and that participation in sports events outside India fell within the disputed application of income. On examination of the impugned order, the Court held that the Revenue had not demonstrated any error warranting interference.

Conclusion: No substantial question of law arose for consideration, and the Revenue's challenge failed.

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