2014 (4) TMI 1217

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.... registration under S.12AA of the Act. 2. Facts of the case in brief leading to the filing of the present appeal are that the assessee institution, incorporated under Companies Act, 1956, has filed an application in Form No.10A on 3.12.2012, seeking registration under S.12AA of the Act. In view of the said application, a questionnaire was issued to the assessee vide letter dated 6.3.2013, requesting the assessee to produce their original Memorandum of Association, alongwith Certificate of Registration, detailed reply on specific points and also to produce the books of account, bills and vouchers etc. for verification. The Director of Income-tax(Exemption), on perusal of the replies to the questionnaire and other information and record pr....

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.... Exemption) rejected the application of the assessee filed in Form 10A of the Act, and consequently, the other application filed in Form 10G seeking approval under S.80G(5)was also rejected. 3. Aggrieved, assessee is in appeal before us. 4. The learned counsel for the assessee submitted that the Director of Income-tax(Exemption) was not correct in holding the nature of activities of the assessee as of commercial nature. It is also submitted that notwithstanding the evidence furnished by the assessee, the Director of Income-tax(Exemption) was not justified in holding that the assessee has not maintained proper receipts for the donations received, and consequently holding that the assessee's source for the deposits of Rs. 4,97,950 in th....