Neuro Update Chennai Vs ITO (ITAT Chennai)
ITAT Chennai held that neurology conferences and workshops squarely fall within the ambit of education under section 2(15) of the Income Tax Act. Hence, exemption under section 11 cannot be denied. Accordingly, appeal allowed.
Facts- During the assessment proceedings AO found that the assessee had conducted 3 seminars / conference during the impugned assessment year at Chennai on advancement of neurology. Hence, AO of the view that the assessee’s activity cannot be called as charitable and hence proposed to deny the exemption. Further, AO stated that the activities of the trust are not covered under education, relief to the poor, medical relief, preservation of environment and preservation of monuments or places or objects of artistic or historic interest. Therefore, the activities have to be examined as to whether it can be said that they fall within the ambit ‘advancement of any other general public utility’. Since, the assessee had collected the sponsorship and advertisement charges from Pharma companies to the tune of Rs.2.21 crores and Delegate fees of Rs.32.28 lakhs, AO concluded that the gross receipts is in the nature of trade, business and commerce and denied the exemption.
CIT(A) upheld the order of AO. Being aggrieved, the present appeal has been filed.
