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TMI Blog2023 (4) TMI 948X X X X Extracts X X X X X X X X Extracts X X X X ..... the absence of any rebuttal by the assessee society, we do not see any reason to interfere in the findings of authorities below, the same is hereby affirmed. Grounds raised by the assessee in this appeal are hence, dismissed. - ITA No.676/Del/2018 - - - Dated:- 20-4-2023 - Shri Kul Bharat, Judicial Member And Shri M Balaganesh, Accountant Member For the Appellant : None For the Respondent : Shri P.Praveen Sidharth, CIT DR ORDER PER KUL BHARAT, JM : The present appeal filed by the assessee for the assessment year NIL is directed against the order of Ld. CIT(Exemption), Chandigarh dated 30.11.2017. 2. The assessee has raised following grounds of appeal:- 1. On the facts and circumstances of the case, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... adverse inference despite the assessee bringing on record all evidences and explanations in respect of the various queries raised by him. 8. On the facts and circumstances of the case, Ld.CIT(E) has erred both on facts and in law in drawing adverse inference misinterpreting the financials of the assessee. 9. The appellant craves leave to add, amend or alter any of the grounds of appeal. 3. At the time of hearing, no one attended the proceedings on behalf of the assessee. It is seen from the record that neither any one has been attending the proceedings since 14.07.2021 nor any request has been filed for adjournment of hearing of appeal on behalf of the assessee. Under these facts, the appeal is taken up for hearing in the ab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed by the applicant, it is observed that the figures of donations for the months of February and March, 2017 remained the same and donations pertaining to rest of the months i.e. from April, 2016 to January, 2016 have been manipulated to reply the query accordingly. This contention of applicant is certainly not acceptable it clearly leads to conclude that applicant is manipulating with the donations received. The issue further get impinged by the fact that the donations are received in cash and whole of the same is not routed through banking channel. In light of the above, this also leads to conclude that the accounts of the applicant are not reliable. It is pertinent to mention that the applicant is managing its activities on cash basis wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... licant has not legal force. The contention that the same is being given by the Sarpanch or Panchayat in no sense makes it clear whether the title over the land vests with the Sarpanch /Panchayat, to that extent applicant failed to establish the income which it sought to be exempted from the vested property. 8. Further the applicant has not elaborated on (a) the target group from whom the donation would be sought/received, (b) the exact contours of the expansion they wish to undertake and the quantum of finances that would be necessary and (c) the list of people who have shown the inclination to donate to the society. 9. Keeping in view all of above it is safe to conclude that both the activities of the applicant are not transparen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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