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TMI Blog2021 (4) TMI 488X X X X Extracts X X X X X X X X Extracts X X X X ..... nature of the objects of the assessee society is concerned, the CIT (Exemption) has not doubted the charitable nature of the objects which are duly stated in the memorandum and rules of the society and available with the Commissioner (Exemption). The only precondition which the assessee was required to satisfy the Commissioner (Exemption) is the genuineness of the activity to achieve the objects of the assessee society. So far as the confirmation of the donations are concerned since the assessee has explained the cause of incomplete confirmation as time constrains therefore, we find that the assessee ought to have been granted sufficient time for submitting the confirmation of donations. The second objection is regarding the genuineness ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at activities of the appellant remains unverified, therefore the applicant looses its eligibility for registration under section 12AA(1)(b)(ii) of the Income Tax Act, 1961. 2. Because the learned Commissioner of Income Tax (Exemption) fails to appreciate the fact that applicant society is doing its charitable activities in the rural and remote area and furnished the complete details of service rendered to the society, the finding to the contrary is based on conjecture and surmises and not on the basis of any material on record. 3. Because the order appealed against is contrary to the facts, law and principle of natural justice. 3. The Ld. AR of the assessee has submitted that the assessee has filed the application in Form No. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essee trust. The Ld. AR has submitted that the Commissioner (Exemption) never asked the assessee to submit those details or bills as well as photographs. Even otherwise photographs for organizing the medical camp is not required. Thus, the Ld. AR has contended that the assessee has furnished relevant particulars as well as documentary evidence in support of the donations and also filed the books of account showing all the details of the expenditure incurred by the assessee which is duly audited. He has thus pleaded that the impugned order may be set aside and the Commissioner may be directed to grant the registration u/s. 12A of the Income Tax Act. 4. On the other hand, the Ld. CIT DR has submitted that the CIT (Exemption) has given vari ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Commissioner (Exemption) thus observed that the donations to the tune of ₹ 2,94,000/- remain unverified. Similarly, for the F.Y. 2017-18, the Commissioner (Exemption) observed that the assessee did not submit any confirmation of donations. The assessee has explained that the confirmation of the local donors were submitted along with written submission on 24.01.2020 and due to the paucity of time the assessee could not furnished the confirmation of the outside donations. It is apparent that the assessee has furnished the written submission and the confirmation of the local donors on the very next date when the Commissioner asked the assessee to submit the confirmation of donations. Since the order was also passed on 30.01.2020 therefor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . So far as the confirmation of the donations are concerned since the assessee has explained the cause of incomplete confirmation as time constrains therefore, we find that the assessee ought to have been granted sufficient time for submitting the confirmation of donations. The second objection is regarding the genuineness of the activities and proof of providing the medical services to the poor by organizing medical camp running medical clinics. Though, the Commissioner (Exemption) has observed that the said claim is not supported by the evidence however, we find force in the contention of the assessee that the assessee was not specifically asked by the Commissioner to produce such evidence. Accordingly, in the facts and circumstances of t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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