2011 (4) TMI 1526

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....ssessee is directed against the order passed by the ld. CIT(A) on 29/30.9.2008 u/s 12AA(1)(b)(ii) of IT Act, on the following grounds: "1 That the ld. CIT-III, Ludhiana wrongly rejected the appellant's application for registration u/s 12A of Income-tax Act." "2 That the ld. CIT-III, Ludhiana has wrongly failed to properly and correctly appreciate the nature of activities carried on by the app....

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....e Government of Punjab, Department of Housing and Urban Development vide its notification dated 21.12.2008 for proper development and re-development of area falling within the Revenue district of Ludhiana and Phillaur Tehsil of Jalandhar. The assessee submitted an application before the ld. CIT, Ludhiana in Form No. 10A on 31.3.2008 seeking registration u/s 12A(assessing authority) of Income-tax A....

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.... the benefits of Sec 12A/12AA which were meant for charitable trust or charitable institute were not available to the assessee. In this connection he has referred to the provisions of Section 12A of Income-tax Act. 3. Aggrieved by the order passed by the ld. CIT, the assessee is now in appeal before this Tribunal. At the time of hearing, the Ld. Counsel for the assessee fairly submitted that the ....

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....onsidered their submissions. Perusal of para 5 of the order passed by the ld. CIT shows that the PUDA Branch of Ludhiana has been dissolved forming a new authority known as Greater Ludhiana Area Development Authority. It is quite obvious that the activities which were earlier undertaken by PUDA at Ludhiana had not been taken over by the assessee. Therefore, there is similarities in the facts and c....