Nadigar Sangam Charitable Trust v. ADIT (2019) 263 Taxman 648/ 179 DTR 297/ 310 CTR 483 (Mad.)(HC)

S. 11 : Property held for charitable purposes – Artists and actors -Advance paid to purchase leasehold right in auditorium was to be considered as application of income- Entitle to exemption.[ S.2(15) 11(1)(a), 11(5)]

AO held that advance amount given by assessee was an investment and could not be treated as application of income towards object of trust  therefore is  not entitled to exemption, which is affirmed by the Tribunal. On appeal High Court held that advance paid by assessee to purchase leasehold right in auditorium is to be considered as application of income within meaning of S.11(1)(a) hence entitle to exemption.  (AY. 2001-02)