2017 (8) TMI 1748

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....e circumstances of the case and in law, the learned CIT(Exemption) has erred in rejecting the application for 80G of the Income Tax Act, 1961 particularly when the assessee is registered u/s 12A of the Act. 2. That on the facts and in the circumstances of the case and in law, the learned CIT(Exemption) has taken into irrelevant consideration for rejecting the case of the assessee u/s 80G of the Income tax Act, 1961. 3. That on the facts and in the circumstances of the case and in law, the learned CIT(Exemption) has erred in giving a finding that the trustees or other persons have claimed deduction u/s 80G of the Act without verifying the same from the returns of the trustees and other persons. 4. That in any case, the assessee is e....

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....of Balance sheet it is also revealed that main focus of the society is only on creation of land and building. This issue also gets exacerbated by the fact at the moment u/s 12AA was received by the society there was host of donations. No donations have come forth in the preceding years during which the trust was in existence. Moreover, taking of loan from M/s V.K. Cogin Mills, especially for the purpose of creation of building makes dear the main intent of the society and that being asset creation and not pursuing any of the state objects that have been professed. 7. Keeping into view all, I am of the considered view that the applicant hasn't been able to justify its quest for approval seeking exemptions on donations made to the enti....