2014 (1) TMI 1666

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....tural justice. 2. That the Commissioner of Income-tax has failed to appreciate that the fact of year under consideration was first year of trust as it come into existence on 22/04/2010 3. That the Commissioner of Income-Tax has failed to appreciate that entire detail called for by authorities below has been submitted wherein no defects have been brought to the knowledge of the applicant. 4. That the ratio applied by the learned Commissioner is not applicable as the society in ratio was receiving from and lending money to its members whereas in the case of trust in question has been created for philanthropic for purpose and not for the purpose of profit. 5. That the order of rejection of application under section 12AA is illegal and runs....

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....ply for land, building, premises or construct the building. (f) To publish newspaper, journal, magazine either daily fortnightly or monthly basis. Ld. CIT was of the view that from the plain reading of any of the above said objects, it could not be said that any purpose of charity was served by those two objects. He, therefore, rejected the application for registration under section 12AA of the Act. Now, the assessee is in appeal. 4. Ld. Counsel for the assessee submitted that the main objects of the assessee are charitable in nature, therefore, it was eligible for registration under section 12AA of the Act. He further submitted that the Ld. CIT rejected the application by observing that the trust had been created on 22/04/2010, but it h....