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TMI Blog2017 (7) TMI 862X X X X Extracts X X X X X X X X Extracts X X X X ..... ll the objectives 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 vouc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 and patronize such talented artists in such manner so that their talent is not extinguished or goes waste or unnoticed. d. To provide platform or opportunities to such artists so that they are able to demonstrate their talent. To provide an opportunity to these artists to represent, serve and lead their country. e. To conduct and sponsor programme, charitable shows, functions that address the area of development and recognition of talent of artists and generate public awareness with regard to artist and his talent and which promote the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ification. 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 produced for verification. Therefore there is no basis for arbitrary disallowance of adhoc 30% of expenditure stated under the head 'Operating and Administrative Expenses' amounting to ₹ 5,20,086/-. These expenses were spent by way of application of income for the purpose of carrying on the charitable activity and such application of income is fully admissible u/s 11. 4. He invited our attention to various letters of the person from whom the assessee has received the sponsorship and the money for the same was spent for the main objects of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aid 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 for the purpose of advancement of various traditional music forms of State of Tamil Nadu, which is an integral part of cultural life of people of Tamil Nadu, cannot also be considered to be an activity in the nature of trade, commerce and business. This can at the best be considered as an educational pursuit. When there are colleges run for coaching music, we cannot say that training imparted in music is not education. In our opinion, the Id. DIT(E) took a very narrow view in this regard and came to a conclusion that the sponsorship fee and music coa ..... X X X X Extracts X X X X X X X X Extracts X X X X
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