2021 (11) TMI 210

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....lowing grounds of appeal:- "(1) The learned Pr. CIT(Exemptions),Ahmedabad's order is contradictory to law and facts of the case and hence, liable to be quashed. (2) The learned Pr. CIT (Exemptions), Ahmedabad has erred in denying for registration u/s 12AA of the Act without considering on merits the documentary evidences/explanations furnished before him to satisfy himself about the objects and genuineness of the charitable and public activities carried out towards the objects of the trust by the appellant trust and hence, the Pr. CIT's action in refusing for registration is arbitrary, without jurisdiction, bad in law and not justified." 2. Brief facts of the case are that assessee is a trust. The assessee filed application for seeking....

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....ties. The Ld. PCIT(E) rejected the application by taking the view that assessee has failed to filed documentary evidence to satisfy about the genuineness of activities in consonance with its object in its order dated 18.09.2017. Thus, aggrieved by the order of Ld. PCIT(E) assessee has filed present appeal before us. 4. We have heard the submission of Ld. Authorized Representative (AR) for the assessee and Ld. Commissioner of Income Tax-Departmental Representative (CIT-DR) for Revenue. The Ld. AR of the assessee submits that while filing application under section 12AA on 08.03.2017 the assessee furnish complete details as required under Form 10A r.w.s. Rule 11AA of Income tax Rules. The assessee explained its object to help poor and note bo....

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....led by assessee in this regard were not verified by him. 5. On the other hand, Ld. CIT-DR for the Revenue supported the order of Ld. PCIT(E). The Ld. CIT-DR for the revenue submits that Ld. PCIT(E) in para- 4 to 6 that impugned order clearly held that assessee failed to furnish requisite details. The Ld. PCIT(E) passed the impugned order on the basis of material available on record. The assessee has not carried out any charitable activity nor establish for the purpose to undertake the charitable activity. It is clearly held that assessee-trust has no intention to start charitable or religious activity and in absence of any documentary evidence, Ld. PCIT(E) was not satisfied himself about the genuineness of activities in consonance with its....