9911796707
TMI Blog2021 (12) TMI 705X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee that it is imparting First Aid training to students, schools, companies and institutions etc and in lieu thereof, charging fees from participants. We find that the receipts shown by the assessee are in the nature of fees for rendering services. These facts have not been disputed by the AO. Objects of General Public Utility do not fall under any of these specific categories explicitly included in the definition of Advancement of any other object of General Public Utility u/s 2(15) of the Act. There is no denial that the assessee society is imparting education and therefore, in our considered opinion, proviso to section 2(15) of the Act is not applicable to the assessee on the facts of the case. The undisputed fact is t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ining paramedics in the field of first aid, home nursing, hygiene safety and first-aid, fire safety, health and stress management, heart mark and care with CPR system, health management with diabetes care and Aids and Disaster management etc. 4. For imparting the above education there are booklets and published material which is provided to the students at subsidized costs. The above education and training programs are carried on at its centers in classrooms with trained lecturers including doctors and other specialists from the field. For providing above education, the guidelines for the lecturers and/or trainers are well laid out and documented for the assistance and guidance of lecturers and for providing proper education to the stude ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e and receipts are more than ₹ 10 lakhs, the activities carried on by the assessee falls under Advancement of any other object of public utility and accordingly, applying proviso to section 2(15) of the Act, income of the assessee was assessed as normal AOP and denied exemption of income u/ss 11 12 of the Act and treated the whole of the surplus generated from business activities and taxed the same as normal business income. 8. The assessee carried the matter before the ld. CIT(A) and vehemently contended that the activities of the assessee society are same as they were in the past years and the Revenue has accepted the activities of the assessee as charitable activities. 9. After considering the facts and submissions, the l ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... specific categories explicitly included in the definition of Advancement of any other object of General Public Utility u/s 2(15) of the Act. There is no denial that the assessee society is imparting education and therefore, in our considered opinion, proviso to section 2(15) of the Act is not applicable to the assessee on the facts of the case. 15. The undisputed fact is that the assessee has been granted exemption since past many years and the nature of activities have not changed since its inception. Therefore, we do not find any reason why the Assessing Officer has taken a different view during the year under consideration. Considering the facts of the case in totality, in light of assessment history of the assessee, we do not find ..... X X X X Extracts X X X X X X X X Extracts X X X X
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