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Issues involved:
The judgment addresses six substantial questions of law raised by the revenue in the appeal. Issue i: The first issue questions the justification of granting exemption u/s. 11 of the Act for income from conducting exhibitions, arguing that such income should be taxable as income from business if not incidental to the trust's objects. Issue ii: The second issue challenges the Tribunal's decision to grant exemption, disregarding the AO's findings that mere maintenance of cash books/ledger is insufficient to meet the requirement of maintaining separate books of accounts for exhibition activity. Issue iii: The third issue questions whether the assessee fulfilled the conditions u/s 11(4)(A) of the I.T. Act, 1961, and thus entitled to exemption u/s 11 of the Act. Issue iv: The fourth issue raises concerns about the Tribunal ignoring past assessments where organizing trade fairs were considered business activities, as defined in Sec. 2(15) of the I.T. Act, 1961. Issue v: The fifth issue challenges the Tribunal's direction to set off deficits from earlier years against the surplus of the current year, considering it as an application of income for charitable purposes. Issue vi: The sixth issue questions the Tribunal's decision to ignore precedents set by the Rajasthan High Court and the Mumbai Tribunal in similar cases. The Court dismissed the appeal, stating that questions 1 to 4 were similar to a previous case dismissed that day, and thus could not be entertained. Question 5 was based on a decision of the Court and was not entertained. As question 6 was consequential, it also could not be entertained. The appeal was ultimately dismissed with no order as to costs.
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