2019 (4) TMI 1291

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....facts relevant for disposal of this appeal are as under:- 2.1 The assessee trust, established by trust deed dated 20.03.2010, 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 03.11.2017. Letters 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 14.05.2018 on the grounds that since the details of activities carried out as submitted by the trust were without mentioning any date and pla....

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....n conducted is wrong. 4. The Learned Commissioner of Income Tax (Exemption) ought to have considered all the facts and based on the letter enclosing the photographs details of various activities conducted show that the Trust has been conducting Charitable Activities. 5. For the above any other Grounds that may be advanced at the time of hearing the Appellant pray the Hon'ble members to direct the Learned Commissioner of Income Tax (Exemption) to allow Recognition of Sec. 80G of Income Tax Act, 1961. 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) on 03.11.2017.....

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....d the order of the CIT(E) rejecting the assessee's application for grant of recognition under section 80G of the Act. 4.3.1 We have considered the rival contentions and perused the material on record; including the judicial pronouncements cited / relied upon. The undisputed facts, as emerge from a perusal of the record before us, is that the assessee - trust established vide Trust Deed dated 20.03.2010, simultaneously filed applications for grant of registration under section 12AA and grant of recognition under section 80G of the Act on 03.11.2017. Clarifications / details were called for thereon by the CIT(E) and the assessee's reply for both grant of registration under section 12AA and recognition under section 80G of the Act was filed....