2021 (1) TMI 999

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....y the appellant in the present appeal relates to the denying of registration by the ld. Commissioner of Income Tax, Exemption, Pune u/s 12AA of the Act. 3. Briefly, the facts of the case are that the appellant is a trust registered under the Bombay Public Trust Act, 1950 on 31.01.1983. The trust was formed with the following objects :- "a. Conducting all the functions related to Sant Zolebaba temple, b. Conducting Yatra, c. Celebrating Death Anniversary (Punyatitthi) d. Providing accommodation to Yatra Pilgrims, e. Providing religious and philosophical education (above points are at S.no 1 to 6 of object clause of trust deed at Encl.5) f. Providing Free Medical facilities to the needy....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....order of ld. Commissioner of Income Tax, Exemption, Pune, the appellant society is before us in the present appeal. 7. Before us, it is submitted that the issue of grant of registration and assessment of income are distinct and separate. Ld. AR for the assessee relied on the decision of the Pune Bench of the Tribunal in the case of Vastushodh Foundation vs. CIT vide ITA No.562/PUN/2016 dated 29.01.2019 and the judgement of the Hon'ble Rajasthan High Court at Jaipur Bench in the case of CIT vs. Shekhawati Public School Samiti in Income Tax Appeal No.173/2018 dated 10.07.2018. 8. On the other hand, ld. CIT-DR placed heavily reliance on the order of the ld. Commissioner of Income Tax, Exemption, Pune. 9. We heard the rival submissions....