TaxTMI 
TaxTMI 
2025 (6) TMI 1326
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....n 19.02.1991 and the same was formed with the main aim of promoting 'Education' which itself is a charitable activity. Ever since its inception, it has been pursuing the sole activity of Education i.e., by running schools for imparting primary and high school education for economically lower and middle class with the approval of the State Government. It is maintaining its regular books of accounts and the same are being regularly audited by the Chartered Accountants and also regularly filing it's IT returns. In compliance with the amended provisions of the I.T Act, 1961, the Assessee obtained provisional registration u/sec.12A of the Income Tax Act, 1961 [in short "the Act"] on 07.02.2024 in Form- 10AC for the assessment year 2024-2025 to 2....
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....ration is herewith rejected". He, accordingly, submitted that, the learned CIT(E) failed to appreciate that, the activity of 'Education' itself is a charitable activity and, therefore, he submitted that, learned CIT(E) may be directed to grant registration u/sec.12A of the Act, in the interest of poor students at large who are unable to bear the education expenses. 4. Shri B. Bala Krishna, learned CIT-DR, on the other hand, supporting the order of learned CIT(E) submitted that, the assessee-society has made the application for registration in Form-10AB for registration u/sec.12AB of the Act. He further submitted that, since the assessee-society has failed to prove it's onus of charitable activities carried-out by it with supporting documen....
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....ensurate with as per objectives of the registered deed/MOA/ AOA, which is in violation of the provisions of the sec. 12A of the I.T Act, 1961. However, the fact remains that, the learned CIT(E) has failed to appreciate that, the assessee-society is running schools from the last 25 years and imparting 'Education' to the economically lower and middle class students with the approval of the State Government. We further note that, imparting 'Education' itself is a charitable activity and the Fundamental Right of every student of this country enshrined under Article 21A of the Constitution of India. Further, the learned CIT(E) without appreciating the relevant evidences filed by the assessee, in a casual manner rejected the application filed in ....