2018 (3) TMI 1760
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....n facts in confirming the action of AO in holding that the appellant is not entitled to exemptions u/s 11 & 12 of the Act on the ground that the activities carried out by the appellant is not falling within S.2(15) of the Act. 2. The learned CIT(A) has grossly erred in law and on facts while not considering that the 63rd National Conference of the Indian Radiological and Imaging Association was held by the appellant trust in Ahmedabad was in context of its objects as per Rules of Association. 3. The learned CIT(A) has grossly erred in law and on facts in considering extraneous and irrelevant materials which is searched from Google without putting it to the assessee. Moreover, the said facts or materials have even not been considered o....
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....receipts are, as such, commercial receipts. The Assessing officer was also of the view that "activity of the trust is nothing but devise by eminent radiologists to promote their own brand/profile etc. by arranging the comfortable stay, food and other facilities to participants" which will lead to "increase the income of the participants which cannot be considered as charitable activity". Accordingly, the income from the activity of holding seminar was held to be commercial activity. Aggrieved, assessee carried the matter in appeal before the learned CIT(A) but without any success. The assessee is not satisfied and is in further appeal before us. 4. We have heard the rival contentions, perused the material on record and duly considered fac....
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....efit to the common public. Except holding of this conference and corresponding donation, the charitable objects, as per the trust deed, have not been challenged by the DIT(E). If the objects of the trust are duly incorporated and charitable in nature and conform to the various rules and regulations; the assessee trust maintains its books of account and the genuineness of the account is established by the society, in normal circumstances the registration should be granted to the Trust u/s 12AA and 80-G of the I.T. Act. The scheme of the Income-tax Act provides - (i) procedure at the time of registration and thereafter (ii) rules for assessment of trusts. Since at the time of registration assessee trust is newly formed, therefore, only the ob....