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TMI Blog2016 (11) TMI 972X X X X Extracts X X X X X X X X Extracts X X X X ..... with the submissions inasmuchas the impugned order categorically records that except for the fact of non filing of documents no other objection had been raised by the Commissioner Income Tax about the genuineness of the activities of the assessee trust. In such a situation, such a finding of fact having been recorded and without there being any element of perversity in the same or any other adv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the CIT has given an incorrect finding. The assessee has duly submitted the evidence for the purchase of land for the establishment of degree college therefore, in our considered opinion, rejecting the genuineness of the activities merely on the basis that the asseessee failed to submit the documents for the purchase of land for the establishment of degree college under section 12(1) (a), no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... satisfied about the genuineness of the activities of the assessee. For giving this finding, the CIT only relied that the assessee has not submitted the documents for the purchase of land for the establishment of degree college but we noted from the documents available on record that the assessee has duly complied with the requirement as desired by CIT. The assesse has duly submitted the copy of r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under section 12 AA (a)(1) (b) is allowed. We have considered the submissions raised. Learned counsel for the appellant submits that as a matter of fact the material that was placed before the Commissioner Income tax was not sufficient enough to record a satisfaction with regard to the status of the activities of the assessee, and in such circumstances the matter ought to have been remande ..... X X X X Extracts X X X X X X X X Extracts X X X X
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