9911796707
TMI Blog2025 (1) TMI 1051X X X X Extracts X X X X X X X X Extracts X X X X ..... that there was no requisition of supporting documents, hence, assessee could not provide the same, thus prayed an opportunity may be granted to the assessee to provide the necessary documents and submissions before the CIT (E) in the interest of justice - HELD THAT:- As DR did not have any serious objection to the proposition made by assessee, we deem it fit and proper to remit back the issues in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o be set aside. 2. On the facts and circumstances of the case and the law, the Ld. CIT(E) has erred in not appreciating the facts available on record while deciding genuineness of the activity. 3. On the facts and circumstances of the case and the law, the Ld. CIT(E) has erred in not appreciating that the very purpose of incurring employee related expenditure was to aid and further pursue the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... under second proviso to clause (ii)(b)(B) of section 80G(5) of the Act is arbitrary and bad in law and deserves to be set aside. 2. On the facts and circumstances of the case and the law, the Ld. CIT(E) has erred in not appreciating the facts available on record while deciding genuineness of the activity. 3. On the facts and circumstances of the case and the law, the Ld. CIT(E) has erred in no ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at assessee has filed an application for registration of trust under section 12AB of the Act on 27.9.2023 in Form No. 10AB under Rule 17A of the I.T. Rules, 1962. Similarly, assessee has also filed an application for grant of approval u/s. 80G of the Act on 27.9.2023 in Form No. 10AB under Rule 11AA of the I.T. Rules, 1962. Both the applications were rejected by the CIT (Exemption), Lucknow. Again ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of justice. Ld. DR did not have any serious objection to the proposition made by the Ld. AR for the assessee. 6. In view of the aforesaid facts and circumstances of the case and in the interest of justice, we deem it fit and proper to remit back the issues in both the appeals to the file of the Ld. CIT (Exemption), Lucknow with the directions to decide the same, afresh, after giving adequate opp ..... X X X X Extracts X X X X X X X X Extracts X X X X
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