2010 (4) TMI 908

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.... are that the assessee-trust was created on July 17, 2007 by one Shri S. Jeyaraj who was declared as the president and was earlier engaged in the activities of religious preaching and a few small token charitable activities since 1992. The Commissioner of Income-tax found that there was no information regarding the socio-economic background, educational qualification, professional competence of the trustees to run a charitable or even a religious trust. Regarding religious activities, the learned Commissioner of Income-tax was of the opinion that though Shri Jeyaraj was a preacher by profession, the role of other trustees was not known and the basic qualification for teaching Christian religion as per ecclesiastical norms of any of the trus....

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....d on the decision of the Allahabad High Court in the case of Fifth Generation Education Society v. CIT [1990] 185 ITR 634 and the decision of the Madras High Court in the case of New Life in Christ Evangelistic Association v. CIT [2000] 246 ITR 532. Per contra, the learned Departmental representative relied on the orders of the Commissioner of Income-tax and reiterated the contents of the same as his submission before us. We have heard the rival submissions and considered the facts and materials on record. We find from the order of the Commissioner of Income-tax that while considering granting of registration under section 12AA of the Act he has gone into the capacity of the trustees, credentials of the trustees, qualification of the ....