9911796707
TMI Blog2011 (9) TMI 1193X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee is directed against the order of the Commissioner of Income Tax, Ludhiana-I passed u/s 12AA(1)(b)(ii) of the Income-tax Act,1961 ( in short 'the Act') dated 30.11.2007. 2. In this appeal, the assessee has taken the following Grounds : "1. That the order u/s 12AA(1)(b)(ii) of the Income-tax Act,1961 passed by the ld. Commissioner of Income-tax-I, Ludhiana is against law and facts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mmissioner of Income Tax has rejected the application, observing as under : "2. A perusal of the documents shows that the Trust came into existence on 04.02.2000 and application for registration was filed on 31.05.2007. The assessee has submitted that the delay in filing of application u/s 12A was unavailability of Counsel of the Trust. This cannot be held as sufficient reason for delay infilli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion as the provisions of this Section are not applicable to it. It is neither a university nor educational institution existing solely for educational purpose and wholly or substantially financed by the Government. The conduct of the assessee is thus not in accordance with the provisions of law. 4. Keeping in view the above facts and circumstances of the case, a letter No.3385 dated 06.11.2007 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... observed that as per the report of the AO and the Joint Commissioner of Income Tax, Range-II Ludhiana, the assessee Trust has not performed any charitable activities during the assessment year 2004-05 to 2006-07. We find that the reports of the AO and the Joint Commissioner of Income Tax, Ludhiana have not been confronted to the assessee. It is a violation of principle of natural justice. As rega ..... X X X X Extracts X X X X X X X X Extracts X X X X
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