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TMI Blog2014 (3) TMI 574X X X X Extracts X X X X X X X X Extracts X X X X ..... G. The assessee has raised following grounds of appeal to challenge the impugned order:- "On the facts and in the circumstances of the case and in law the learned DIT(E) erred in rejecting the application under section 80G without appreciating the information nfiled with regard to the entire donation receipts with its corpus details and confirmations by the appellant during the course of proceedings; therefore, the impugned order suffer from failure of natural justice sans merits and the same may be vacated on the ground of perversity. Without prejudice to the above, on the same set of facts and circumstances the Revenue has already issued under section 80G. Denial of 80G renewal of flimsy ground is not justified." 2. When the case was c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... count of administrative expenses, the assessee submitted that it has taken the premise on rent which is used for the charitable activities like "blood donation camp", "gyansala", "survadharm sammelan" and other similar activities as given in the objects. The details of these activities have been given by the assessee vide letter dated 29th February 2012. Later on, the assessee again furnished the detail submissions on 26 th March 2012 and 28th March 2012, the relevant portion of which have been incorporated by the learned DIT(E). However, the assessee's application has been rejected by him on the following grounds:- "5. The submission made by the trust is duly considered. In the list of donors as submitted by the trust on 23.12.2011, n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... idence which has been incurred on the objects of the trust. 5. After considering the relevant findings of the learned DIT(E), which has been incorporated in the impugned order itself, and also the submission of the learned Departmental Representative, it is seen that the learned DIT(E) has not culled out in his order as to which are the conditions laid down in clauses (i) to (v) of sub-section (v) of section 80G, have not been fulfilled by the assessee trust. If the learned DIT(E) is satisfied that one or more of the conditions laid down in the said clauses have not been fulfilled, he can reject the application for approval after recording his reasons. In the present case, it has not been brought on record by the Revenue as to which of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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