2012 (10) TMI 442

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....rut, refusing to grant approval to the respondent trust under Section 80-G of the Act. 3. The respondent-assessee is an Educational Trust and was granted registration under Section12-AA of the Act vide certificate dated 30.9.2005 w.e.f. 1st April, 2004. The registration is still valid. It was also granted approval under Section 80-G of the Act, which was to expire on 31.3.2009, for which an application for renewal was made on 9.6.2009. 4. The Commissioner of Income Tax, Meerut rejected the renewal application on 17.12.2009 on the ground that during the course of hearing and examination of the application as well as details furnished by the Trust, it was stated that the trust is engaged in providing vocational education to the students bel....

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....y the assesses and that even otherwise such activities are also charitable activities, and thus these could not be considered to be a reason for non-grant of renewal to the assessee under Section 80-G (5) (iv). 6. Shri Dhananjay Awasthi has pressed following grounds in support of his contention:- "1. Whether in the facts and circumstances of the case, the Income Tax Appellate Tribunal has erred in law in directing that exemption u/s 80-G (5) (vi) of the I.T. Act, 1961 may granted to the assessee on the sole ground that the assessee had been granted registration u/s 12-A of the I.T. Act, previously, when the fact remains that Section 12-A and Section 80-G are entirely exclusive of each other and grant of registration u/s 12-A of the IT Act....