2019 (3) TMI 1163

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....'). 2. The facts relevant for disposal of this appeal are as under:- 2.1 The assessee trust, established by trust deed dated 21.12.2016, filed applications for grant of registration under section 12AA of the Act and for grant of recognition under section 80G of the Act simultaneously on 16.01.2018. Letters dated 24.04.2018 and 27.06.2018 were issued by the CIT(E) to the assessee calling for details / clarifications thereon. In this regard, the assessee submitted replies. The CIT(E), after considering the details filed, rejected the assessee's application seeking grant of recognition under section 80G of the Act vide the impugned order dated 25.07.2018 on the grounds that the activities of the trust are not charitable in nature and tha....

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....dispute. 4.1 Before us, the learned AR for the assessee submitted that its applications for grant of registration under section 12AA of the Act and for recognition under section 80G of the Act were both filed before the CIT(E) on16.01.2018. Details and clarifications thereon were called for jointly by the CIT(E) vide letters dated 24.04.2018 and 27.06.2018 and the assessee also filed its reply in this regard vide letters dated 21.06.2018 and 13.07.2018. It is submitted that while the CIT(E) dismissed the assessee's application for grant of recognition under section 80G of the Act vide the impugned order dated 25.07.2018, the CIT(E) however went on to grant the assessee recognition under section 12AA of the Act vide order dated 25.07.2018....

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.... undisputed facts, as emerge from a perusal of the record before us, is that the assessee - trust established vide Trust Deed dated 21.12.2016, simultaneously filed applications for grant of registration under section 12AA and grant of recognition under section 80G of the Act on 16.01.2018. Clarifications / details were called for thereon jointly vide CIT(E)'s letters dated 24.04.2018 and 27.06.2018 and the assessee's reply for both grant of registration under section 12AA and recognition under section 80G of the Act was filed vide letters dated 21.06.2018 and 13.07.2018. From the impugned order, we find that the main objection by the CIT(E) to grant of recognition under section 80G of the Act was that the assessee trust has not carried out....