2019 (1) TMI 2042

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....ner of Income Tax on 28-02-2014. The Commissioner of Income Tax vide order dated 25-08-2014 passed u/s. 80G rejected the application for approval u/s. 80G inter alia for reason that the assessee society was engaged in commercial activities and the activities conducted by assessee cannot be considered as charitable activities. Aggrieved by the order of Commissioner of Income Tax, the assessee is now before us and has raised following grounds : "1. That under the facts & the law, the learned Commissioner of Income Tax erred in rejecting the application filed by the appellant for approval U/s. 80G (80G(2)(a)(iv) arbitrarily & without properly considering & appraising the facts explained before him. Prayed to that the appellan....

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....its institute on commercial lines and providing commercial education for a fee which cannot be considered as education it is not a formal education, is contrary to the facts as the education imparted by the assessee are affiliated to the various universities, the details on which are placed at pages 3 to 4 of the paper book. He therefore, submitted that when the registration u/s. 12A to the assessee is still being continued, the Commissioner of Income Tax could not have rejected the application u/s. 80G and for this proposition he relied on the decision of Agra Bench of the Tribunal in the case of Dr. Gyanendra Goel Foundation Vs. Commissioner of Income Tax reported in (2018) 52 CCH 284 (Agra), the copy of which is placed in the paper book.....