2018 (2) TMI 43

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....vocate, Shri Sachin Bajpai, Advocate For the Respondent : Shri V. B. Sargar, D. R. ORDER PER MANISH BORAD, A.M. This appeal of the assessee is directed against the order of CIT-II, Jabalpur dated 29/05/2014. The assessee has raised seven ground of appeal but the sole grievance is against the order of CIT not granting approval for registration u/s 12AA of the Act. 2. Briefly stated, ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... therefrom were not provided to learned CIT. Looking to these facts, the CIT was of the view that the claim of society being a non profit educational institution, per se, providing education cannot be treated as deed of charity in view of the huge surplus earned consistently for last so many years. He accordingly applied the decision of Madras Tribunal in case of Rajah Sir Annamalai Chettiar Found....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....k running from page 1 to 65 and submitted that the CIT failed to appreciate this fact in right perspective denying approval for registration u/s 12AA of the Act. 4. On the other hand Learned D.R. supported the order of learned CIT. 5. We have heard rival contentions and perused the record placed before us. The assessee is aggrieved with the order or CIT not granting approval u/s 12AA of the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t in fixed assets, per se, cannot prove that the assessee is not engaged in charitable activities. 5.1 In the light of above observations, we observe that CIT has rejected the application u/s 12AA without considering relevant facts, financial statements, gazette notification of State Government and examining the activities carried out by the assessee in detail. Both the 4 parties have no ....