TMI Blog2023 (1) TMI 1290X X X X Extracts X X X X X X X X Extracts X X X X ..... ial surpluses - HELD THAT:- On perusal of the impugned order, we found that the CIT(E) has provided only one opportunity to the assessee to provide the details as sought for, for which, as per assessee could not submit the details within the time. Looking to the above facts and circumstances of the case and in the interest of principle of natural justice, as fairly admitted by both the sides, we s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2AA of the Act ignoring the fact that the appellant is engaged in carrying out the charitable activity as per the objects of the institution. 2. In the facts and circumstances of the case and in law the Id. Commissioner of Income-tax, Exemption, Bhopal has erred in refusing to register the appellant institution u/s. 12AA of the Income-tax Act, 1961 without giving proper and reasonable opport ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee society is generating substantial surpluses. On examination of accounts of the society, the CIT(E) also found that the assessee-society has given substantial amount of loans and advances. Therefore, the ld. CIT(E) observed that the assessee society is not carrying out any charitable activity for public at large rather it is generating huge surplus by carrying out its activities by runnin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sessee trust could have produced if the reasonable time was made available to it. It was submitted that the act of the Ld CIT(E) was against the principles of natural justice, illegal and, therefore, the impugned order deserves to be dismissed. 5. On the other hand, ld. CIT-DR relied on the order of ld. CIT(E). 6. We have heard the rival submissions and perused the record carefully. On per ..... X X X X Extracts X X X X X X X X Extracts X X X X
|