2012 (9) TMI 990

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....nt proceedings noted that the main object of the assessee trust was to promote and protect trade, commerce and industries of India and in particular trade, commerce and industries connected with electrical and electronics industries. The AO noted that the assessee earned income of Rs. 5,31,51,351/- from membership subscription, seminars, workshops, IEEMA publications etc.. The AO further noted that the assessee during the year had conducted an exhibition named Elecrama 2008 having gross receipts of Rs. 25,07,95,866/- and after deducting expenses incurred on account of exhibition, net surplus was shown at Rs. 5,57,67,313/- which was claimed as exempt. The AO observed that in the earlier years the activity of organizing trade fair had been co....

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....exhibition every two years the purpose of which was to make known to the public products/electronic goods which in turn promote electronic industries. Thus holding of exhibition was merely ancillary and incidental to the dominant object and once dominant object was held as chargeable, the assessee could not be denied benefit in respect of incidental activities. After considering the submission of the assessee, CIT(A) observed that the Mumbai Bench of the Tribunal in assessee's own case in 1974-75, 1996-97, 2004-05 in ITA No.658/Bom/79 dated 14.1.1980 and in ITA No.5470/Mum/99 dated 21.7.2005 and in ITA No.4736/Mum/2007 dated 18.5.2009 respectively have held that holding of exhibitions was an incidental object and explanation under section 1....

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.... industries connected with electrical and electronic industries. The assessee trust had other ancillary objects one of which was to arrange trade fairs, exhibitions, symposia etc. The dispute is as to whether income from such activities of organizing exhibition etc. is exempt from tax. Under the provisions of section 11(4A), exemption under the said section is not available in respect of any profit and gain arising from business unless business is incidental to attainment of the objectives of the trust and separate books of account are maintained. In this case the AO held that holding exhibition was one of the main objectives. It was held by him that the assessee was not maintaining proper and separate books as only cash book, ledger, bank ....