Deduction under s 44A

The amount expended by assessee, a registered society for the purpose of protection or advancement of the common interest of its members, will be allowable as deduction — as held by DelTrib in ADIT v Hologram Manufacturers Association — In favour of: The assessee.

Profits and Gains of Business — Provisions of s 28(iii) could not be invoked for the purpose of taxing the annual subscription received by the assessee from its members which is as per its Memorandum of Association and Rules and Regulations and receipts relating to subscription on account of international conference.

Exemption under s 2(24)(iia) — Since the assessee has not been granted the benefit of a 11, and it is also not an institution referred to in cl (21), (23) or (23C) of s 10, there is no question of application of s 2(24)(iia).

Decided on: 9 September 2011.