TaxTMI 
TaxTMI 
2018 (1) TMI 1236
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....tificate of registration issued by the Registrar of the Societies. It filed application in Form No.10A on 27.09.2012 seeking registration u/s 12AA of the Act. In order to consider the merits of the said application, the DIT (E) issued a questionnaire vide letter dated 26.12.2012 requiring the assessee to produce the original document of Memorandum of Association, details on specific points and also to produce books of account, bills and vouchers etc., for verification. The assessee filed the relevant information. 3. The DIT (E) observed that the assessee society has claimed to be running two educational institutions i.e. Ken-Crest International School and Ken Crest Global School in Karimnagar Dist. He consider the contentions of the asse....
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.... running schools in the names other than that for which recognition has been granted by the concerned govt. authorities and therefore, the assessee has violated the recognitions granted by the authorities and therefore, the assessee would not be eligible for grant of registration u/s 12AA of the Act. 4. Further, DIT (E) also observed that the assessee has applied for affiliation from University of Cambridge, UK and has paid GBP 4000 (Great Britain Ponds) in November, 2012 towards registration charges etc., in that regard. Since the expenditure has been incurred out of the income of the society outside India, he held that since the income of the society has not been applied only in India, the assessee is not eligible for registration u/s ....
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....subject portion of the letter and not to the contents of the proceedings. Further, he submitted that the registration is to be granted to the society and not to the individual schools and since the society is carrying on the charitable activities, it is eligible for registration u/s 12AA of the Act. He also drew our attention to the proceedings dated 27.09.2013 granting registration u/s 10(23)(C) of the I.T. Act. He submitted that this goes to prove that the assessee is carrying on the educational activities alone and the Department itself has accepted that the assessee's activities are charitable and wholly for the purpose of education. Therefore, the learned Counsel prayed that the assessee should be granted registration u/s 12AA of the A....
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....sessee has not fulfilled conditions for granting of registration u/s 12AA of the Act. 8. Having regard to the rival contentions and the material on record, we find that admittedly the assessee is an institution carrying on educational activities and therefore, it is a charitable institution. Though it has started its activities in the year 1998, it has filed the application for registration u/s 12AA of the Act only on 27.09.2012. We have gone through the approvals of the Educational Officers and we find that in the subject portion referred to the proceedings, the name of the assessee is mentioned as "Ken-Crest High School", whereas in the body of the letter, the name is referred to as "Ken-Crest Global High School", Karimnagar. Further, ....