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TMI Blog2020 (11) TMI 818X X X X Extracts X X X X X X X X Extracts X X X X ..... majority of receipts are by way of fees collection cannot be a ground to refuse recognition u/s. 80G - The assessee is admittedly existing for a charitable purpose of providing education. As rightly contended by the ld. DR, the impugned order is a non-speaking order and therefore it would be in the fitness of things to set aside the order of CIT(E) and remand back to him the issue of grant of rec ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is a charitable trust established vide deed dated 30/03/2001 to establish, run and manage educational institutions, to promote study of all languages, cultures and heritages, to propagate and promote literary and cultural activities and to strive towards the overall development of the society. The assessee trust obtained registration under section 12AA of the Income Tax Act on 02/04/2001 and 80G ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessee submitted that recognition u/s. 80G(5) has to be granted subject to certain conditions being fulfilled as laid down in the said sub-section. Rule 11AA of the Income-tax Rules, 1962 [the Rules] provides that if the conditions mentioned in section 80G(5) are not satisfied, then recognition can be denied. It was pointed out by the ld. counsel for the assessee that in the impugned order, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... recognition u/s. 80G(5) OF THE Act. 5. The ld. DR, on the other hand, supported the order of CIT(E) and submitted that in any event, the matter should be remanded to CIT(E) to pass a speaking order specifying the grounds on which recognition u/s. 80G is being refused. 6. We have carefully considered the rival submissions and are of the view that the impugned order of ld. CIT(E) is a non-spea ..... X X X X Extracts X X X X X X X X Extracts X X X X
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