2020 (12) TMI 118

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.... "1. The learned CIT erred in not granting the registration u/s 12AA to the appellant trust. 2. The learned CIT erred in holding that because the appellant trust had received corpus donations in F.Y. 2018 - 19, the appellant was indulging in profit making activities and the charitable objects were not proved and hence, the appellant trust is not entitled to registration u/s 12AA. 3. The learned CIT failed to appreciate that - a. The objects of the appellant trust are charitable in nature as per section 2(15) of the Act and therefore, registration u/s 12AA ought to have been granted to the trust. b. The appellant had not carried out any non charitable activity. c. The appellant had already appl....

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....ch forms part of the income as per Sec.2(24)(iia) of I.T. Act. According to the ld. Commissioner of Income Tax (Exemptions), on account of the conduct of appellant trust in not showing said receipt as part of voluntary donation escaped the assessment of the income to tax and gave a finding the appellant trust had indulged in activities from which huge receipts have been generated. Accordingly, the ld. Commissioner of Income Tax (Exemptions), concluded that the genuineness of the charitable nature of the activities of the trust are not established and therefore denied the registration under Sec.12AA of the Act vide impugned order. 4. Being aggrieved by the above order of ld. Commissioner of Income Tax (Exemptions), denying the registratio....