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TMI Blog2013 (7) TMI 947X X X X Extracts X X X X X X X X Extracts X X X X ..... n u/s 12AA of the Act on 01-06-2012 before the Commissioner of Income-tax. According to the ld.representative, the object of the trust was to promote ayurveda research, organize seminars, workshop and classes for imparting knowledge about ayurveda. The object also provides for running, developing school, college or other educational institution for the benefit of the people. The assessee also contributes towards medical research in ayurveda. Referring to the impugned order of the Commissioner of Income-tax, the ld.representative submitted that the assessee has conducted various schemes in furtherance of its object. Sale of ayurvedic products manufactured by M/s Dhathri Ayurveda Pvt Ltd was part of the camps conducted by the assessee. Theref ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uxury hotel accessible to the poor people itself is a charitable activity undertook by the assessee. The ld.representative placed his reliance on the judgment of the Punjab Haryana High Court in CIT vs Surya Educational Charitable Trust (2011) 15 taxmann.com 123 (Punj Har) (copy of which is filed by the assessee) and submitted that for registration of the trust u/s 12AA, the Commissioner of Income-tax has to satisfy himself to the genuineness of the trust as he may deem necessary. The object of section 12AA is to examine the genuineness of the object of the trust but not to examine the application of income for charitable or religious purpose. Stage for application of income is only when the trust or institution files its return of in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat sub-section from the stage at which they were on that day. (2) Every order granting or refusing registration under clause (b) of sub-section (1) shall be passed before the expiry of six months from the end of the month in which the application was received under clause (a) or clause (aa) of sub-section (1) of section 12A. (3) Where a trust or an institution has been granted registration under clause (b) of sub-section (1) or has obtained registration at any time under section 12A (as it stood before its amendment by the Finance (No.2) Act, 1996 (33 of 1996) and subsequently the Commissioner is satisfied that the activities of such trust or institution are not genuine or are not being carried out in accordance with the objects of t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ils of the persons invited for the seminars said to be conducted in the luxury hotels are not available on record. The contention of the revenue is that only ayurvedic practioners were invited for seminars. Therefore, the assesse is promoting the products manufactured by M/s Dhathri Ayurveda Pvt Ltd through the ayurvedic practioners by conducting the seminars. The details of seminars are also not available on record. In the statement of facts, the assessee claims that various camps were conducted by the trust in co-ordination with other institutions, who are having similar objects. The assessee has also filed before this Tribunal bills for purchase of certain ayurvedic medicines which are said to be distributed to the people in the course o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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