2011 (10) TMI 418

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....pta, J. - The Revenue has raised the following substantial questions of law:  (i)  Whether on the facts and in law, the Hon'ble Income Tax Appellate Tribunal was justified in holding that the manner of application of funds of trust do not fall within the purview of the Commissioner of Income Tax while examining application seeking registration u/s 12 AA of the Act, whereas such exa....

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....o the assessee, when the Applicant Institution was carrying out the activities for the benefits of persons having substantial interest in the garb of 'charitable activity'? 2. Similar questions of law were also raised in ITA No.701 of 2010 titled CIT v. Surya Educational & Charitable Trust [2011] 15 taxmann.com 123 (Punj. & Har.) to the following effect:   "** ** **  On....

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....ncome from consideration under Section 10(22) now 10(23)(C) or Sections 11 and 12 are not applicable while considering the application for registration under Section 12AA of the Act. The application for registration is required to be made within one year of the creation of the Trust. Section 12AA of the Act, requires satisfaction in respect of the genuineness of the activities of the Trust, which ....