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2025 (6) TMI 1387

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....come Tax Act, 1961 [in short "the Act"], respectively. 2. Brief facts of the case are that, the assessee-trust society viz., Fighting First Trust has been registered with Registrar of Societies under the Registration of Societies Act, 2001 and incorporated on 06.02.2023 with an avowed object of rendering service to the community of serving and retired personnel and their families of First Batallion, The Mechanised Infantry Regiment Madras of the Indian Army, without any distinction or irrespective of religion, caste of creed. The objects of the assessee-trust are - * Providing financial assistance to widows, dependent parents and children of serving and retired personnel. * Awarding scholarships and fellowships in cash or in such other....

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.... evidences. During the course of proceedings, the learned CIT(E) called for certain information i.e., to produce the copy of Memorandum of Association/Trust deed for verification and to furnish a detailed reply. In response to the same, the assessee has submitted partial information. Therefore, the learned CIT(E) issued another notice dated 29.10.2024 to submit the other information along with relevant documentary evidences. In response to the said notice, the assessee-trust has filed relevant submissions before the learned CIT(E). The learned CIT(E) after considering the submissions of the assessee trust observed that, no substantial charitable activities are carried-out by the assessee trust, which is in violation of provisions of section....

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....rdance with law. He, therefore, submitted that, the learned CIT(E) may be directed for registration of the assessee-trust u/sec. 12AB of the Act and approval be granted u/sec. 80G of the Act in the interest of substantial justice. 6. Shri Narender Kumar Naik, learned CIT-DR, on the other hand, supporting the orders of learned CIT(E) submitted that, the assessee-trust has made the application for registration in Form-10AB for registration u/sec. 12AB and for approval u/sec. 80G 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 documents to the satisfaction of the learned CIT(E), he rejected the application filed by the assessee-society i....