2018 (4) TMI 1712

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.... appeal. "1. That the order dated 28.03.2017 passed under section 12AA of the Income Tax Act 1961 is against law and facts on the file. 2. That CIT (Exemptions) erred in making observations in Para 2 of the order "that none of the stated objects seems to have been pursued by the applicant trust". Learned CIT (Exemptions) states in Para 6 of the order that income and expenditure account for the F.Y. 2015-2016 reveals that approximately 86% of the total receipts has been spent under the head "To Uiiaqar Singh Aulakh Hospital" apart from other heads of expenditure of general nature". Observation in Para 2 of the order is against facts and law. 3. That learned CIT (Exemptions) has failed to appreciate factual written ....

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....etters received from various doctors for reimbursement of visiting fees to the aforesaid hospital during the year: 2016-17 till 10.02.2017, however, it was observed by the Ld. CIT(E) that all the thirty two letters are handwritten by the same person and is severally dated from 13th April, 2016 to 10th February, 2017 which clearly shows that the letters have been framed to cover the specific queries raised on the relationship between the applicant trust and hospital because no other evidence in support of the claim has been submitted. Similarly self-generated letters have been submitted by the applicant trust for the year 2015-16 detailing list of patients, who got treated in the hospital. It was further observed by the Ld. CIT(E) that altho....

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....es to different specialist doctors during the financial year 2015-16, which is not in controversy and list of the patient also supports the assessee case that the poor patients are being treated at the hospital, therefore we have failed to understand as to what evidences, the Ld. CIT(E) required for further confirmation from the beneficiaries of the trust. In the instant case, the objects of the trust are not in controversy which is first consideration for grant of registration u/s 12AA of the Act. Secondly, the trust is at nascent stage and during the Financial Year 2015-16 having received donation to the extent of Rs. 1,12,000/- only and maximum of (Rs. 1,03,250/-), which has already been utilized for the charitable purposes as it reflect....