2022 (10) TMI 981

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....cussion. 2. The appellants, Sir Ratan Tata Trust and Sir Dorabji Tata Trust (hereinafter referred to as 'the assessees') by filing the present appeals, sought to set aside the impugned orders dated 01.010.2021 & 02.10.2021 passed by Principal Commissioner of Income Tax, Mumbai [hereinafter referred to as the PCIT] qua the assessment year 2022-23 to 2026-27on on identically worded grounds inter alia that :- "1. The Learned Principal Commissioner of Income-Tax (PCIT)/ Commissioner of Tncome-Tax (CIT) grossly erred in issuing order granting registration under section 80G of the Income Tax Act, 1961 (ITA) dated 02.10.2021 which imposed conditions on the basis of which the registration was granted, even though there is no provision i....

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.... the Ld. Lower Revenue Authorities and documents available on record in the light of the facts and circumstances of the case and law applicable thereto. 6. Undisputedly, the Ld. PCIT has granted the approval applied for by the assessee under section 80G of the Ac, however, subject to the conditions as under: "a. No change in the deed of the applicant trust/society/non profit company or any of its bye-laws shall be affected without the due procedure of law and the approval of the Competent Authority as per provisions of law and its intimation shall be given immediately to Office of the Jurisdictional Commissioner of Income Tax and to the Assessing Officer. b. Any change in the trustees or address of the applicant trust/s....

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....nt shall not be used, directly or indirectly, for the purposes of such business and a certificate shall be issued to every person making a donation to the effect that the applicant maintains separate books of account in respect of the business and the donation received by it will not be used, directly or indirectly, for. the purpose of the business. i. The applicant shall comply with the provisions of the Income Tax Act, 1961 read with the Income Tax Rules, 1962. j. The approval and the Unique registration number has been instantly granted and if, at any point of time, it is noticed that form for approval has not been duly filled in by not providing, fully or partly, or by providing false or incorrect information or docume....