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TMI Blog2021 (12) TMI 393X X X X Extracts X X X X X X X X Extracts X X X X ..... d 30/5/2015 and has obtain Registration u/s 12AA w.e.f 1/4/2016 vide order dated 23/2/2017. At the time of grant of Registration u/s 12AA, the assessee has given details about the purpose and object of the applicant trust which was related to the religious purposes and not for any other business purpose. CIT(Exemption) has totally ignored the fact that the purpose was not at all change from the charitable purpose to any commercial purpose. In-fact, there is no proper reason given by the CIT(Exemption) while rejecting the prerequisite for approval u/s 80G. Therefore, we are directing the CIT(Exemption) after verifying all the documents as per the pre-required conditions of grant of Section 80G benefits and thereafter grant the benefit of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on record along with reply dated 14/12/2017.. 4. That, the findings arrived at by the learned CIT (Exemption) about the appellant trust s activities being not charitable are contrary to the facts and circumstances of the appellant trust s case and material placed by it on record before him and runs contrary to the findings of the CIT (Exemption), Lucknow on basis of which the appellant trust was granted registration vide latter s order dated 23.02.20M under section 12AA of the Act. The appellant trust has carried on similar activities post registration under section 12AA of the act, thus it cannot be held that the activities are commercial or noncharitable in nature. 5. That, the learned CIT (Exemption) has erred on facts i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Income Tax Act, 1961 w.e.f 1/4/2016 vide letter dated 23/2/2017. The assessee trust filed its application for the grant of Registration u/s 80G of the Income Tax Act, on 5/4/2017 in the prescribed format. Notice dated 13/11/2017 was issued by the CIT(Exemption) thereby asking submission of certain documentary details and information along with opportunity of being heard. The assessee submitted reply dated 14/12/2017 containing complete and elaborate response to each query of the CIT(Exemption). The CIT(Exemption) vide order dated 14/12/2017 rejected the application of the assessee thereby stating that the assessee is not indicated in any chargeable purpose which is the pre-requisite for approval u/s 80G. 4. Being aggrieved by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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