2015 (3) TMI 537

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... g trade fairs and therefore not engaged in business activity. We find that there is certainly a distinction/difference between organizing trade fairs and facilitating its members to participate in trade fairs. Consequently, once there are concurrent findings of fact that no trade fair is organized by the respondentassessee which would amount to carrying the business, there is no occasion to us to .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... sessment Year 2005-06. The impugned order dated 10 August 2012 dismiss the Revenue's appeal from order dated 17 November 2008 passed by the Commissioner of Income Tax (Appeals) (the 'CIT(A)') directing the Assessing Officer to allow the respondentassessee exemption under Section 11 of the Act. 2. The following question of law has been formulated by the appellantrevenue for our consi .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ritable purpose. Consequently the Assessing Officer by his order dated 31 December 2007 denied the benefit of exemption under Section 11 of the Act. 4. On appeal, the CIT (A) on consideration of the facts concluded that the objects of the respondentassessee are charitable in nature and covered within meaning of charitable purpose as defined in Section 2(15) of the Act. The CIT(A) held that the .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... e subsequent assessment year a similar view has been taken by the CIT (A) and the revenue has not challenged the same even before the Tribunal. 6. The grievance of the revenue is that there is no difference in facilitating its members to participate in trade fairs and from one organizing trade fairs. Therefore it is submitted the conclusions arrived by the CIT (A) as well as the Tribunal cannot .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... tivity. We find that there is certainly a distinction/difference between organizing trade fairs and facilitating its members to participate in trade fairs. Consequently, once there are concurrent findings of fact that no trade fair is organized by the respondentassessee which would amount to carrying the business, there is no occasion to us to interfere with the same. The finding recorded by the a .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X