2023 (6) TMI 872

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ENA, AM: The captioned appeal is filed by the assessee against the order of the learned principal Commissioner of income tax exemption, Chandigarh dated 29.11.2017, challenging therein, rejection of its application for grant of approval under section 80G (5) of the income tax act, 1961, by raising the following grounds: 1. The Ld. CIT(Exemptions) has erred in law and facts by not giving approva....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n form 10G dated 29.05.2017 in the office of Commissioner of income tax exemption for approval under section 80G (5) of the income tax act, 1961. The Ld. CIT (exemption) stated that the assessee is only running a school and collecting fee from the students. He has categorically stated that the real purpose of the trust is altogether different from the stated object in the memorandum of the society....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... CIT (exemption) has rejected the application of the appellant for grant of approval under section 80G (5) of the income tax act. 5. After hearing the Ld. DR at length, and considering the material facts available on record, we found that appellant trust has been running a school, and raising funds by way of collection of fee from the students, bus fees, hostel fee, etc., during previous financi....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....rstly the activities of trade, commerce, or business, or connected to achievement of its object of general public utility in relation thereto, does not exceed the quantified limits that is 20% of total receipts of the previous year. In our view, the appellant trust is required to file fresh application for grant of registration under section 2(15) and consequently, the application for approval und....