2022 (7) TMI 860

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....t the Ld. Commissioner of Income Tax (Exemptions) has erred in matter of law and fact by passing his order under section 80G(5)(vi) of the Income-tax Act, 1961 ('Act) for rejection of the application of the applicant under section 80G of the Act. 2. That the Ld. Commissioner of Income Tax (Exemptions)has grossly erred in matter of fact and law by holding that the 'activity' of the applicant involves serving of liquor. 3. That the Ld. Commissioner of Income Tax (Exemptions)has grossly erred in matter of law and fact in taking an unreasonable decision of rejecting the application of the applicant under section 80G without considering the charitable activities of the applicant. 4. That each of the above mentioned gro....

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....n the above with cogent evidence. I am further directed to inform you that in case of failure to comply with this letter, an inference will be drawn that you have no explanation to offer and the matter/application filed in Form 10G will be decided on merits. Your reply/explanation in this regard should reach this office by 26/07/2019." 4. The Appellant has filed reply and after considering the reply, the Commissioner of Income Tax (Exemption) held that, the activity involving serving of liquor cannot be set to be charitable, usage of money collected from donors is to be utilized for welfare of general public, not for enjoyment of people enjoying the state of affairs of the federation. The serving of the liquor cannot be consider....