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TMI Blog2024 (11) TMI 223X X X X Extracts X X X X X X X X Extracts X X X X ..... e activities are for the benefit of public at large - There is no reference of the information submitted on that date in the order of the ld CIT (E) , thus, it is true that the learned CIT(E) has issued the show cause notice on 01.02.2024 but there is no reference of the details submitted on 12.01.2024 and how same is dealt with by the learned CIT(E). The observation of the CIT(E) has raised seven points which was not stated to have been replied by the assessee and, therefore, it was held that the learned CIT(E) was not able to draw any satisfactory conclusion about the genuineness of the activities and compliance of requirement of any other law. Regarding the genuineness of the activities the assessee has provided the details of various ex ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... certified Rule 17A(2)(a) by the trustee, which is an inadvertent error. ii) Details of date place of each activity were not furnished by the Trust but the CIT[E] overlooked the fact it is not possible to provide because public come and attend spiritual lectures, swadhyay etc. iii) Details of donation received were not supported by complete postal address/ PAN of the donors, receipt no. ete by overlooking the fact that details of petry donations were already furnished on 12-1-24 for 3 last years, iv) By overlooking submissions made on 12-1-24 comprising of 97 pages showing expenses incurred on objects of trust. v) Refusing to give adjournment filed in 8-2-24 for filing more details of earmarked funds, Paushadshala hall fund, Ayambil bhavan f ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... furnished details. He found several discrepancies. Based on this, the assessee was specifically informed that in the event of failure to comply by the due date the application would be rejected. The due date was 08.02.2024, the assessee did not furnish any information and, therefore, the learned CIT(E) dismissed the application of the assessee. Provisional registration granted was also cancelled. Therefore, the assessee is in appeal before us. 04. The learned Authorized Representative (AR) submitted a paper book containing 364 pages to support his case stating that the details have been submitted before learned CIT(E). He referred to the activities of the assessee placing reliance on the trust deed submitted on Page 45 of the paper book. H ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he paper book. There is no reference of the information submitted on that date in the order of the ld CIT (E) Thus, it is true that the learned CIT(E) has issued the show cause notice on 01.02.2024 but there is no reference of the details submitted on 12.01.2024 and how same is dealt with by the learned CIT(E). The observation of the CIT(E) has raised seven points which was not stated to have been replied by the assessee and, therefore, it was held that the learned CIT(E) was not able to draw any satisfactory conclusion about the genuineness of the activities and compliance of requirement of any other law. Regarding the genuineness of the activities the assessee has provided the details of various expenditure of various activities for the y ..... X X X X Extracts X X X X X X X X Extracts X X X X
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