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TMI Blog2021 (5) TMI 81X X X X Extracts X X X X X X X X Extracts X X X X ..... see moved an application in Form 10G on 19/08/1918 for grant of approval U/s 80G of the Act. The assessee Trust was created on 19/10/1964 and is registered U/s 12AA of the Act since 01/03/1976. The ld. CIT(E) after receiving application from the assessee, raised certain queries/clarifications which are mentioned in para 2 of the impugned order. For the cost of repetition, the same are not reproduced herein. The ld. CIT(E) observed that no reply was furnished by the assessee, therefore, another opportunity was given. In response to which, the assessee furnished submissions on 08/02/2019. The ld. CIT(E) again raised additional queries vide letter dated 09/02/2019. In response, the assessee furnished reply, however, the ld. CIT(E) considered t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the objects did not pertain to any particular religion but to the Saints, Priests and other wisemen of all the religions and the assessee Trust provides free accommodation to those persons, so that, they can impart their knowledge for the welfare of the general public without cast and creed and without any inclination to any specific religion. Reliance was placed on the judgement of Chandigarh Bench of ITAT in the case of Maharaja Aggarsain Charitable Trust Vs CIT reported in 87 taxmann.com 153. Copy of the said order was furnished which is placed on the record. Reliance was also placed on the following case laws: (i) Umaid Charitable Trust Vs Union of India (2008) 171 taxmann 94 (Raj HC) (ii) Shiv Mandir Devasthan Panch Committee S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d primarily establish Geeta Bhawan with in the prescints of Mandi Barnala, to provide for the accommodation to learned Sadhus, Saints and Preists, for the propagation and dissemination of Dharmik Shiksha." From the aforesaid objective of the assessee Trust, it is clear that the assessee Trust established Geeta Bhawan to provide accommodation to Sadhus, Saints and Priests for the propagation and dissemination of Dharmik Shiksha. From the aforesaid object, it is very much clear that the accommodation was provided to those persons who were propagating and disseminating Dharmik Shiksha in the society as a whole and not to a particular community or religion. Moreover, the said persons are also not related to a particular religion or community ..... X X X X Extracts X X X X X X X X Extracts X X X X
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