2012 (8) TMI 390

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....hin the meaning of Section 2(15), it was granted registration/approval under section 12A vide order dated 27-1-1999. In pursuance to that, it has also been granted certificate under Section 80G from time to time. The last certificate under Section 80G was applicable upto 31-3-2007. Accordingly, the assessee vide application dated 14-3-2007 has applied for grant of certificate under Section 80G from 1-4-2007 onwards. 3. Learned DIT(E) noticed that the applicant trust had not carried out any charitable activities in the last three years and had not incurred any expenditure, he, therefore, issued a show cause notice to provide certain details and also as to why the application under Section 80G should not be rejected. In the impugned order ....

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.... our attention to various financial audited statements, wherein he showed that expenditures incurred have been capitalized. The relevant submissions of the assessee as was filed before the DIT(E), which has a vital bearing in the case, for the sake of ready reference is reproduced herein below :- "In our last meeting your goodselves desired us to explain as to how the work carried out by our client would make them eligible for 80G approval. At the outset, we draw your kind attention to the fact that the present application before your goodselves is an 80G renewal application. Further as regards the query raised, our submissions are as follows: The main object 'of the trust reads as under: "To Endeavour to protect, preserve and nour....

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....e are engaged for maintaining the Tadpatras in good condition and for administrative purposes. The trust is capitalizing all the expenditure incurred in Orissa for making manuscripts of various literatures on Tadpatra since many years. The expenditure includes purchase of Palm leaves, preparation of Tadpatra on which literature can be inscribed, payments to writers and proof readers and etc. Also the salaries paid at Orissa are capitalised. The expenditure incurred in further proof reading is treated as revenue expenditure. We may mention the fact that the trust was granted the certificate u/s. 80G on 28.06.1999 for a period of 2 years from 26.03.1999 to 31.03.2001 which was renewed twice to grant 80G status for a period of 2 years from ....