9911796707
TMI Blog2022 (6) TMI 568X X X X Extracts X X X X X X X X Extracts X X X X ..... framed u/s 143(3) of the Income Tax Act, 1961 (in short the "Act") dated 03.06.2015. 2. Registry has informed that the present appeal is time barred by 311 days. On going through the affidavit filed by the assessee stating the reasons for the said delay, we find that the assessee received incomplete order as eleven pages were not available. The assessee made necessary efforts to get the remaining missing pages and finally succeeded in getting the same in September, 2019 and thereafter, immediately filed the appeal. We find sufficient force and reasonable cause for such delay and thus, condone the same and admit the appeal for adjudication on merit. 3. The assessee is in appeal before the Tribunal raising the following grounds: "1) The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... trained or in appropriate cases to prepare them to instruct others in the principles and practices of management. (c) Further according to Clause 6(a) of the ancillary objects of the institute is to do all such other lawful things as may be necessarily incidental or conducive to the attainment of the above objects, Organizing of Golf Cup tournament is incidental to the attaining of the main object of the institute to equip the students the roughly to practice the art and profession of the management. 3) The provisions of Section 11(4A) as mentioned in the Appeal order does not apply as organizing of Golf tournament is not a business activity. 4) Considering the various practical knowledge earned by the students in organizing the Golf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rred were not for educational purposes as golf is a costly game and in this case only industrial houses have appeared and participated in golf tournament and since the assessee does not maintain books of account as per Section 11(4A) of the Act, therefore, it cannot be said that the expenditure was incurred for educational purposes. 6. Aggrieved, the assessee is in appeal before this Tribunal. 7. Ld. Counsel for the assessee submitted that it is true that the assessee exists solely for educational purposes, however, with an aim of connecting corporates and academia with the ultimate and long-standing objective in order to provide avenues for employment to students through close interaction and networking with the corporate entities, such ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e said event cannot be said to be a part of the educational activity for which the Trust is established. Therefore, so far as golf tournament is concerned the said activity is not educational activity. 12. As regards the quantum of disallowance of golf tournament expenses is concerned, we find that the golf tournament is a separate activity carried out by the assessee Trust for which it received sponsorship of Rs. 30,17,250/- from various corporates and the same is duly reflected in the credit side of income and expenditure account of the assessee Trust and this fact has been well taken note of by the ld. AO also in the assessment order. Therefore, the excess expenditure incurred by the assessee Trust on the said golf tournament amounts to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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