2021 (7) TMI 576

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....missioner of Income Tax (Exemptions), Hyderabad, rejecting application filed by the Appellant for approval u/s.80G of the Income Tax Act, 1961 is perverse and unsustainable in law and on facts. 2. The finding of CIT(E) that the Appellant is operating for the benefit of other entities in which the trustees are directors j partners is incorrect. The CIT(E) gave this finding without properly appreciating the facts in correct perspective. 3. The inferences drawn by the CIT(E) on the aspects of office premises of the Appellant being located at the residential premises of Sri Vasudeva Reddy, and on the said person being a Director of M/s. Lake View Tennis Academy Pvt. Ltd. and owner of land on which Appellant is constructing tennis court are ....

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....tive. 8. On the facts and in the circumstances of the case, all the findings and observations of the CIT(E) in his order are incorrect and are made only with a purpose of denying 80G approval to the Appellant and for issuing show cause notice for cancellation of registration ul s.12A gran ted earlier. For these and other grounds that may be urged at the time of hearing, it is prayed that the Hon'ble Tribunal may be pleased to allow the appeal." 2. Briefly the facts of the case are that the assessee filed application in form 10G seeking approval u/s 80G of the Act on 27/10/2018. CIT(E) issued a notice dated 01/03/2019 to the assessee to appear and produce its original memorandum of association/trust deed, note on activities of insti....