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2023 (10) TMI 1414

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..... s and it is seen that it is genuinely carrying out its activities towards charitable objects. Therefore, it cannot be said that assessee has not filed any evidences for the charitable activities carried out by it. Apart from that, in so far as allegation that assessee has not submitted the details of share transaction is also incorrect, because as pointed out by the ld. Counsel equity shares of Valiant Organics Ltd. were sold and the assessee company / trust has received the shares in the form of donation and the copy of share donation letter has also been placed before us. The entire details of the shares sold and received by the company towards its corpus for carrying out charitable activities is evident from the record. Thus there is not .....

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..... observed that the assessee had not furnished details regarding the assessee's share transactions and documentary evidence of the charitable activity carried out by the assessee. Accordingly, a notice was issued to the applicant vide DIN Notice No. ITBA/EXM/F/EXM43/2022-23/1049909427(1) dated 20.02.2023 requesting the assessee to submit the aforementioned details and to show cause why the application for approval should not be rejected in absence of the same. 4. Though the assessee has made submission on 23.02.2023, the same do not speak about the charitable activities conducted by the trust. The assessee's submission has been carefully perused. However, the documents provided by the assessee do not prove the genuineness of the acti .....

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..... r which has also been placed in the paper book. He has also given a detail note of charitable activities carried out by the assessee alongwith the proofs of donation given to institutions and students for various charitable activities. Thus, he submitted that the ld. CIT (Exemptions) has wrongly rejected the application for approval u/s.80G. 4. On the other hand, ld. DR submitted that, let these documents be examined by the ld. CIT (Exemptions) again and matter should be restored back to the file of the ld. CIT (Exemptions), as he has not considered these documents or given any finding on such documents. 5. After considering the facts and material placed on record and also on perusal of the impugned order, we find that ld. CIT (Exemptions) .....

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..... Tribes, Backward Classes 5) Minorities and senior citizens 6) Physically challenged persons 6. Before us, assessee had placed various documentary evidences wherein it has given donations for various charitable activities which are appearing from pages 11-74. None of these documents have been examined or gone through. From the bare perusal of these documents it is seen that assessee has given donations for various charitable activities and to students for their scholarships and other aids and it is seen that it is genuinely carrying out its activities towards charitable objects. Therefore, it cannot be said that assessee has not filed any evidences for the charitable activities carried out by it. Apart from that, in so far as allegation that .....

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