TMI Blog2014 (8) TMI 693X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Act, 1961 arises from a decision of the Income Tax Appellate Tribunal dated 31 October 2013. By the impugned order, the Tribunal has set aside the order dated 4 December 2012 passed under Section 80G(5)(vi) by the Commissioner of Income Tax, Meerut and has ordered that the exemption under Section 80G be granted to the assessee. The revenue has raised several questions of law of wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... activities and advertisements, seminars and meeting activities. These activities, by no means, fall in the domain of 'charitable purpose' as defined in section 2(15) of the I.T. Act, 1961. Activities of the Trust are in the nature of research work which may or may not benefit the general public depending upon the future outcome. Trust has failed to prove as to how the general public has be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot only on the ground that the registration under Section 12AA had been refused but independently also on the ground that the audited accounts indicated that the Trust had not carried out any activity in aid of a charitable purpose as defined under Section 2(15). In fact, the conclusion in paragraph 7 which has been noted above, would indicate that both the reasons, namely (i) that the Trust had n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 12AA. Since this premise is erroneous, we are of the view that the ends of justice would require that the proceedings be restored back to the Tribunal for a fresh decision. We clarify, in the circumstances, that it is not necessary for the Court to express any view on the questions of law raised. For the reasons indicated above, we allow the appeal by restoring the proceeding back to the Tribuna ..... X X X X Extracts X X X X X X X X Extracts X X X X
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