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TMI Blog2021 (7) TMI 936X X X X Extracts X X X X X X X X Extracts X X X X ..... missed. - I.T.A. No. 1659/Del/2018 - - - Dated:- 15-7-2021 - N.K. Billaiya, Member (A) And Mahavir Prasad, Member (J) Revenue by : Sh. Gaurav Pundir, Sr. DR Assessee by : None ORDER Per Mahavir Prasad, J M This appeal has been filed on behalf of the Revenue against the order of Ld. CIT(A) No. 325/2016-17/1567 order dated 04.12.2017. The Revenue has taken the following grounds of appeal:- 1. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in allowing the exemption u/s. 11 12 of the Income Tax Act, 1961 to the assessee ignoring the fact that the assessee is doing activities which are in nature of trade, commerce or business and since the receipts from trade, commerce or busines ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 377; 1,08,11,857/- ii) Quality Application Assessment Accreditation fees ₹ 22,56,36,486/- iii) Quality Conclave Seminar Receipts ₹ 33,54,069/- iv) Honorarium, Sale of Quality Literature Misc. receipts ₹ 2,45,211/- v) Improvement in Health Services Initiatives ₹ 2,57,14,551/- vi) Membership Fees ₹ 12,52,847/- The assessee has shown following major expenditures against the above receipts: i) Salary Allowance Benefit ₹ 6,19,49,992/- ii) Administration other Expenses ₹ 12,42,77,807/- iii) National Quality Campaign ₹ 1,68,20,065/- iv) Depreciation ₹ 33,49,552/- 3. Thereafter, a show-cause notice was issued by the Assessing Officer ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ld. AO did not agree with the contention of the assessee and made addition of ₹ 62024427/-. Against the assessment order assessee preferred first statutory appeal before the Ld. CIT(A) who granted relief to the assessee holding that the QCI activities are of charitable purpose u/s. 2(15) of the Income Tax Act and allowed exemption in AY 2009-10, 2010-11, 2011-12, 2012-13 and 2013-14 and further held that in ITAT in ITA No. 867/2016 in appellant's own case it was ruled out that on the basis of Court's judgment in India Trade Promotion Organization vs. DGIT (2015) 374 ITR 333 and in the case of Institution of the Chartered Accountants Vs. DGIT(Exemption) (2013 358 ITR 91) (Del.) that mere circumstances of collection of such amo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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