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TMI Blog2025 (2) TMI 601X X X X Extracts X X X X X X X X Extracts X X X X ..... public connected together and society at large. The reliance on the decision of Tribunal in case of Brahmakshatriya Kanji Damji Hindu Sarvajanik Dharamshala Palitana [2024 (12) TMI 1532 - ITAT AHMEDABAD] has also mentioned the decision of CIT vs. Dawoodi Bohara Jamat which was relied upon by the DR and has categorically mentioned the jurisdictional High Court in the case of Jamiatul Bannat Tankaria [2024 (10) TMI 712 - GUJARAT HIGH COURT] which has given interpretation of Section 13(1)(b) while issuing registration u/s 12A of the Act. Thus, the decision relied by the DR actually supports the applicant Trust's case. The Hon'ble Supreme Court in the case of Shastri Yagnapurush Dasji vs. Muldas Bhudardas Vaishya [1966 (1) TMI 78 - SUPREME ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 03.2024. After going through the applicant's submissions, the CIT (Exemption) observed that the Trust is created by the Patidar Samaj and also it can be seen that out of total eleven objects of the Trust, the objects 1, 3, 4, 5, 8 & 9 are charitable in nature are found to be confined to the caste members of Patidar Samaj and not for general public. Thus, the CIT (Exemption) rejected the applicant's application and cancelled the provisional registration vide order dated 28.03.2024. The applicant filed appeal before us. 4. The Ld. AR submitted that there is a delay of 160 days in filing the present appeal due to the fact that the Managing Trustee of the Trust are not so literate and not having computer knowledge as well as e-mail address als ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aj only and, therefore, provisions of Section 13(1)(b) of the Act would be applicable in the present case. 6. We have heard both the parties and perused all the relevant material available on record. Hon'ble Apex Court in the case of Ahmedabad Rana Caste Association (supra) categorically observed that it is sufficient if intention to benefit a section of public as distinguished from a specified individual and that will not go beyond the purview of public connected together and society at large. The reliance on the decision of Tribunal in case of Brahmakshatriya Kanji Damji Hindu Sarvajanik Dharamshala Palitana (supra) has also mentioned the decision of CIT vs. Dawoodi Bohara Jamat which was relied upon by the Ld. DR and has categorically m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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