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TMI Blog2019 (1) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... ngaged in imparting education in the area of presea and postsea training to seamen and was not carrying out activity in nature of running coaching class. The first question as proposed by the Revenue is, therefore, not entertained. Accumulation u/s 11(2) - loan to other Trust of same objects without investing in modes specified in section 11(5) of the Act even though there is specific provision in section 13(1)(d) - Held that:- Delhi High Court in Director of Income Tax (Exemptions) v/s. ACME Educational Society [2010 (7) TMI 159 - DELHI HIGH COURT] held that grant of interest free loan by the Assessee Society, to another society for carrying on same activity, does not amounts either investment or deposit. Assessee would be entitled to e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the Revenue, Assessee can be seem to have run coaching classes. Revenue, therefore, argued that these, were not charitable activities and the Trust was, therefore, not entitled to exemption under the Income Tax Act, 1961 (for short the Act )'. The Tribunal, however, ruled in favour of the Assessee and allowed the Appeal. Tribunal observed that, Assessee had let out its property to Tata Sky for no other purpose then of giving technical training to its staff from which activities, the Assessee had earned income. The Assessee had also participated in the training programme. During the training, te staff and the trainee of the Jet Airways were allowed access to the play ground and other amenities available to the students. Similarly, in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the Revenue is, therefore, not entertained. 5. The second question pertains to Revenue's objection to the Assessee Trust advancing loan to some other Trusts, carrying on same charitable objects. Learned Counsel for the Assessee drew our attention to the Judgment of the Delhi High Court in Director of Income Tax (Exemptions) v/s. ACME Educational Society reported in 326 ITR 146 which was also relied upon by the Tribunal in the impugned judgment. The Delhi High Court in the said Judgment held that grant of interest free loan by the Assessee Society, to another society for carrying on same activity, does not amounts either investment or deposit. Assessee would be entitled to exemption under the Act. This question, therefore, a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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