2017 (7) TMI 862

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.... CIT (A). 2. I have heard the rival contentions and perused the facts of the case. The society is registered u/s 12A of the Act vide order dated 5.5.2005 and also registered u/s 80G of the Act vide letter dated 8.10.2007. The assessee is the society created with the main objects as under:- "The assessee society is created with the following main objectives:- a. To identify, recognise, promote talent in the field of light folk music, classical music, instrumental music and any other such related music and performing arts. b. To promote, develop and nurture such artists from all parts of India especially from far flung areas like Kashmir, Himanchal Pradesh, Northeastern states etc. c. To promote, develop....

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....ectives of trust are subservient to its main object of promotion of music and music artists in India. Raising the artists taste of the country by public performances, dramatic, musical, etc., would be an educational purposes. The nature of receipts clearly shows that the activities of the assessee trust were wholly and exclusively focused on pursuing its main objects of promoting music in the masses. Further, it was submitted that the AO is factually wrong in alleging that the books of account with supporting bills and vouchers were not produced for verification. The written submissions filed on 01.02.2013 and again on 20.02.2013 duly record that in response to the specific requirement of the A.O, the books of account and vouchers were prod....

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....ch forms substantial part of the amounts listed above, can be considered as receipt from activity in the nature of trade, commerce and business. In our opinion, advancement of traditional musical culture of Tamil Nadu and conducting music programmes for that purpose, where such music and dance programmes were sponsored by various persons and sponsorship fee so received, distributed among the artists, can never be considered as an activity in the nature of trade, commerce or business. When a person sponsors a music programme and sponsorship fee is paid to artist concerned, we cannot say that sponsorship fee is a receipt in the hands of the assessee which is in the nature of trade, commerce or business. Similarly, conducting music coaching fo....