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TMI Blog2019 (3) TMI 1163X X X X Extracts X X X X X X X X Extracts X X X X ..... initially. Grant of approval / recognition under section 80G of the Act can act as a catalyst to encourage prospective donors to look at the intended activities / objects and possibly provide financial support through donations / contributions. Strangely, in the case on hand, on the very same day i.e., 25.07.2018 when he rejected the assessee’s application for recognition under section 80G of the Act, the CIT(E) has granted the assessee-trust registration under section 12AA of the Act vide order dated 25.07.2018; ostensibly, after examination of the assessee’s objects, etc., which the CIT has categorized as “Advancement of any other object of general public utility”. Restore the matter to the file of the CIT(E) to examine the matter afr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itable activities. 2.2 However, as far as the assessee s application for grant of registration under section 12AA of the Act, the CIT(E) by order of even date, as the impugned order, i.e., dated 25.07.2018 has granted the assessee registration; copy of which has been placed at pages 51 and 52 of Paper Book filed by the assessee. 3.0 Aggrieved by the order of CIT(E), Bengaluru, dated 25.07.2018 rejecting the assessee s application for recognition under section 80G, the assessee is in appeal before the Tribunal; wherein it has raised the following grounds:- 1. Having regard to facts and circumstances of the case, The Ld. Commissioner of Income Tax (Exemptions)(CIT-E) has erred in rejecting the application for grant of approval under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bmitted that the CIT has rejected the assesssee s application for registration primarily on the ground that the assessee trust has not carried out any noticeable activities till the formation of the trust and its activities are not charitable. According to the learned AR, there is no requirement in law that the assessee must start doing charitable activities on a large scale before applying for grant of registration under section 80G of the Act. It was contended that since the CIT(E) has granted the assessee trust registration under section 12AA of the Act vide order dated 25.07.2018, it shows that the CIT(E) has already verified its objects and its establishment for charitable purposes while granting registration and therefore the CIT(E) b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e, it was not a fit case for grant of recognition under section 80G of the Act. In our view, what is significant / noticeable activity is very subjective and cannot be the basis for rejection of the assessee s application. It is for the assessee to determine which of its activities in furtherance of its objects are to be taken up initially. Grant of approval / recognition under section 80G of the Act can act as a catalyst to encourage prospective donors to look at the intended activities / objects and possibly provide financial support through donations / contributions. Strangely, in the case on hand, on the very same day i.e., 25.07.2018 when he rejected the assessee s application for recognition under section 80G of the Act, the CIT(E) ha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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