2019 (5) TMI 1773

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.... SHUKLA, J.M.: The aforesaid appeal has been filed by the revenue against impugned order dated 26.10.2015, passed by Ld. CIT (Appeals)-40, New Delhi for the quantum of assessment passed u/s 143(3) for the assessment year 2011-12. In grounds of appeal, revenue has raised following grounds: - 1. "On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in allowing th....

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.... Particulars of Income Amount (Rs. 1. Sports Receipts 67,45,512/- 2. Activities Receipts 1,82,47,487/- 3. Work Experience Receipts 14,66,000/- 3. In response to the show cause notice as to why above receipts may not be taxed as business income, assessee supplied 2 lists of students from whom fee have been charged, one containing list of participants who attended the value education work....

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.... hence, benefit cannot be given to the assessee in view of the proviso to section 2 (15). 4. Before the Ld. CIT(A), assessee strongly relied upon the following judgements of the Hon'ble Delhi High Court in the case of ICAI vs. DGIT (E), 347 ITR 99 (Delhi); and India Trade Promotion Organisation vs. DGIT, 371 ITR 333, (Delhi High Court); and submitted that in view of the principles laid down by th....

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....aterial on record, we find that it is an undisputed fact that assessee was granted registration u/s 12AA. The aims and objects of the assessee society are as under: - a) "Promote Educational research and studies for qualitative growth of the Institution and the child. b) Educational trends in the nature of Academic, Cultural, Arts and Sports, strategic environments through National academic in....