2014 (8) TMI 1024

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....re to promote and popularise education. The Trust was incorporated on 01.06.2009. It deserves to be noticed that the assessee made an application for registration under section 12A of the Act on 27.07.2009 which was rejected by the DIT (Exemption) on 26.02.2010 on the ground that the objects of the Trust extend to the territories beyond India and they are commercial in nature. Thereafter the assessee made appropriate amendments to the Memorandum of Association and object clause and again applied for registration on 20.04.2012. Vide order dated 30.12.2012 the DIT (Exemption) rejected the application. He has taken into consideration the Memorandum of Association and its main object, i.e. "to promote and popularise education in cities ......" ....

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....ifies that such activity would be done only by running a school. In fact the letter indicates the vision of the company, i.e. reviving education in India by raising a school which does not indicate that it has commenced the school but by any mode set out in the main object so that it can help the above mentioned categories in getting some training or knowledge and such activity can be commenced only when the assessee gathers its source of fund. Thus commencement of activity cannot be linked up with granting of registration as otherwise the assessee cannot raise funds. The learned counsel for the assessee submitted that the main object was to set up a charitable Trust and in fact the DIT (Exemption) has denied the claim of registration mainl....