TaxTMI 
TaxTMI 
2025 (9) TMI 708
X X X X Extracts X X X X
X X X X Extracts X X X X
....ppeal before us. The Ld. AR advanced arguments on the strength of various documents as placed on record. It has been stated that the amended objects have not, at all, been considered by Ld. CIT(E). The Ld. CIT-DR also advanced arguments in support of rejection of impugned registration. Having heard rival submissions and upon perusal of case records including the papers as kept before us, the appeal is disposed-off as under. 2. The assessee-society was created on 30-06-1968, inter-alia, to provide services to its members, advise on taxation matters and provide assistance and guidance in import and export formalities. Upon perusal of various documents & explanations as furnished by the assessee, Ld. CIT(E) observed that the main activities....
X X X X Extracts X X X X
X X X X Extracts X X X X
....its amended MOA, seeks to fulfill the following objectives: - 1. Aims & Objects of Chamber/Society i) To represent interests of business, industry and trade with state governments ii) To invite top mentors, industrials, other government dignitaries for the development of industries to provide platform for interaction. iii) To organize useful Seminars, Workshops and Competitions for the members of the Chambers. iv) To lead overseas business delegation and to provide business opportunities for the members. v) To sign MoUs with fantabulous companies which help our members to get benefit out of it. vi) To organize exhibitions for the industries of latest technologies. vii) ....
X X X X Extracts X X X X
X X X X Extracts X X X X
....egal Entity or Individuals to Finance the work. xxi) To accept Donations, Presents, Gifts, Loans and other Offerings in the shape of Moveable or Immoveable properties for the attainment of the Aims and Objective of the Society. xxii) To Establish and Strengthen Partnership with similar National and International groups and exchange information and advice with them. xxiii) To accept the funds/donation in monetary or non monetary terms under CSR (Corporate Social Responsibility Activities) activities from corporate entities for the purpose of Education/skill development activities, job fair for unemployment/under employed youth, any charitable activities, relief to poor, environment protection, promotion of yoga sem....
X X X X Extracts X X X X
X X X X Extracts X X X X
....n admission of members from wide spectrum of public. The perusal of financial statements for FY 2023-24 would show that it is receiving contribution for various purposes which are being utilized towards promotion of its objects only. Considering the fact that the assessee could admit members from wide spectrum, it could not be said that it was a mutual organization which was running merely for mutual benefit only. The 'advancement of general public utility' as provided u/s 2(15) would be wide enough to cover such kind of activities. The Ld. AR has placed on record date-wise details of charitable activities along with evidences from April, 2023 to March 2024 on Page Nos. 162 to 265 of the paper-book. The perusal of the same would show that t....
X X X X Extracts X X X X
X X X X Extracts X X X X
....t in this decision, it was nowhere been held that the activities carried on by the charitable entity which were supportive to the attainment of main object are to be treated as non-charitable activities. The Hon'ble Court has even held that activities of charging of any amounts towards consideration for any activity (advancing general public utility) which is on cost basis or nominally above cost, cannot be considered to be trade, commerce or business or any services in relation thereto in Para 253 page 82. The Hon'ble Court held as under:- "A.3. Generally, the charging of any amount towards consideration for such an activity (advancing general public utility), which is on cost-basis or nominally above cost, cannot be consi....