2025 (7) TMI 944

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....ainst the rejection of application u/s 12AA of the I.T. Act, 1961, the assessee has raised the following grounds of appeal: ITA No.6/Hyd/2025 "1. The rejection order of the Learned CIT(Exemption) of Income tax is erroneous both on the facts and circumstances of the case and also in Law. 2. Whether, on the facts and in the circumstances of the case, the rejection order of the Learned CIT(Exemption) was perverse in so far in making an observation that there are no substantial charitable activities being carried out by the appellant which are in violation of provisions of section 12A and 80G of the Income tax Act, 1961. 3. The appellant craves to add, modify or delete any other ground that may be urged during the ....

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.... u/s 12AB of the I.T. Act, 1961 and after considering the relevant evidence and details filed by the assessee to show that the assessee has carried out the charitable activities. He has referred to the income & expenditure account as well as the balance sheet of the assessee and submitted that majority of the expenditure is incurred only on education purpose. 4. On the other hand, the learned DR has submitted that though the assessee has furnished its financial statement, however, there is a discrepancy in the details as furnished by the assessee regarding the bills raised by the contractor for construction of the class rooms and other works in the govt. schools and the expenditure booked by the assessee in the income and expenditure acc....

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....being carried out by the assessee trust, which is in violation of provisions of section 11 and 12 of the IT Act, 1961. In light of the above facts, the present application in form 12AB is herewith rejected." 6. As it is revealed from para 3 of the impugned order that in response to the notice, the assessee has submitted the information which was available before the learned CIT(Exemption). However, the application was rejected only on the ground that no substantial charitable activities are being carried out by the assessee trust. Once the assessee has produced the relevant information, details and evidence in the shape of financial statements, bills/invoices raised by the contractor after completion of the construction work of class roo....