Rejection of Section 12AA registration affects Section 11 exemption; deemed speculative and not legally sustainable.

Exemption u/s 11 - rejecting the application filed for registration u/s 12AA - Section 12AA of the Act provides for procedure for registration as to how ld. CIT (E) will provide registration after getting satisfaction with the aims and objects of the society and not to sit on the chair of AO as all these facts ought to be taken care by the AO at the time of assessment. Declining the registration on the ground that medical research to be carried out in the hospital of settler company would convert the charitable activities into commercial activities is mere surmises, hence not sustainable in the eyes of law. - AT .....

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