2021 (4) TMI 96

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....ra, CA& Sh. Sanjay Arora, CA For the Respondent : Sh. N.C.Uppadhay, Sr. DR ORDER PER SUDHANSHU SRIVASTAVA, JM: This appeal has been preferred by the assessee against order dated 29.08.2019 passed by the Learned Commissioner of Income Tax (Exemptions), Lucknow {CIT(E)} rejecting assessee's application seeking approval u/s 80G of the Income Tax Act, 1961 (hereinafter called 'the Act'). ....

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....es, surmises and assuming incorrect facts and, therefore, is bad in law. 2. That on the facts and circumstances of the case and in law, the Hon'ble CIT(Exemptions) has erred rejecting the application filed by the Appellant for registration u/s 80G of the Act, inter alia because: 2.1. The activities performed by the Appellant are covered under the ambit of 'chartitable purpose' as....

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....llant had already been examined and held to be charitable in nature at the time of its registration under section 12AA of the Act. 4. That on the facts and circumstances of the case and in law, the Hon'ble CIT(Exemptions) has erred in holding that no expenditure has been incurred by the Appellant towards charitable objects for which the trust had been formed, inter alia because- ....

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....e Ld. CIT(E). 6.0 Having heard both the parties and after having gone through the records, it is seen that the assessee continues to enjoy registration u/s 12A of the Act and, therefore, their appears to be no apparent reason for which the assessee's request for recognition u/s 80G of the Act was denied. In our considered opinion, interest of substantial justice would be served, if the Ld. CIT(....