AI OCR 
TaxTMI 
TaxTMI 
TaxTMI 
2025 (7) TMI 1666
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....was duly made and executed on 10.02.2025, prior to the passing of the order of rejection. Grounds on significant activities of the Trust: 4. That the learned Commissioner of Income Tax (Exemptions) erred in not denying the fact that one of the appellant's main objectives is provide shelter to and empowerment of women who fall under marginalized groups. 5. That the learned Commissioner of Income Tax (Exemptions) erred in not appreciating the fact that 'empowerment of women' comes under 'advance of any other objects of general public utility'. 6. That the learned Commissioner of Income Tax (Exemptions) erred in not denying the fact that the appellant has incurred major expenses towards shelter to women who fall under marginalized groups. Grounds on expenses incurred towards other activities 7. That the learned Commissioner of Income Tax (Exemptions) erred in not considering the tact that the awareness drives, nutrition and health education, etc., was provided by the employees only who are health workers. Each of the above grounds is without prejudice to one another, the appellant craves the leave of the I hon'ble Income Tax Appellate Tribunal, Ba....
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....nities, including those affected by poverty, abuse, discrimination, and social exclusion. Recognizing the multiple challenges faced by these women, the program is designed to offer both immediate support and long-term empowerment. Through the establishment of safe shelters, the NGO ensures access to basic necessities such as secure accommodation, nutritious food, medical care, and emotional support. These shelters serve as a protective environment where women can begin to heal and regain a sense of security. Beyond providing shelter, the initiative focuses strongly on empowerment-equipping women with the tools and resources they need to build independent lives. This includes life skills education, health awareness, mental health counselling, and access to employment opportunities. The ultimate goal is to restore dignity, promote self-reliance, and support the social and economic integration of marginalized women, enabling them to live with confidence, purpose, and hope. Submissions on Significant activities of the Appellant 2.2. Empowering women, particularly those from disadvantaged or marginalized backgrounds, is a vital component of promoting general public utility as defined ....
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....der the marginalized section of the society. It is stated here that the learned Commissioner of Income Tax (Exemptions) did not recognize the fact that the major expenses were towards shelter, salary and security. Also, the learned CIT(E) stated that the appellant has no significant activity towards the main objectives of the trust. 2.8. Based on the above it can be inferred that there is nexus between the expenses and the charitable activity of the appellant which cannot be denied. The details of expenses incurred and the percentage of the same based on the total expenses is given below: SI.No. Expenditure Head Amount in Rs. % of Total Expense 1. Rent Expense for Beneficiaries 3,73,13,588 53.10% 2. Office Rent 1,84,800 0.26% 3. Staff Salary Paid 1,15,86,740 16.49% 4. Maintenance Charges 13,20,860 1.88% 5. BWSSB - Water Charges 27,66,030 3.94% 6. Electricity Expenses 37,52,794 5.34% 7. Security Guard Charges 81,10,626 11.54% 8. Medical Services 12,95,592 1.84% 9. Accounts & Finance Charges 10,000 0.01% 10. Vehicle Maintance 1,31,324 0.19% 11. Petrol Allowance 94,563 0.13% 12. Stationery Charges 2,74,265 0.39% 13. Travel & Food....
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....nce on expenses related towards awareness drives, nutrition and health education, yoga and aerobics training, etc.,: 3.1. As on 31.03.2025, the appellant has rented a total of 49 Residential Facilities (RFs) to provide shelter, safety, and health support for approximately 4,008 migrant workers. Of these RFs, 5 are designated for male occupants, 43 for female occupants, and 1 facility is shared by both. The details of the beneficiary are provided vide page no .45. to 4.6 of paper book. 3.2. To manage and operate these facilities, the appellant has engaged 106 employees, including Care Takers, Health Workers, Nurses, and Supervisors, who are responsible for the day-to-day functioning of the RFs. These employees are also trained to carry out a range of awareness activities and community engagement programs, including health and nutrition education, hygiene drives, yoga sessions, and aerobics training. 3.3. The no. and the designation of the employees as on 31.03.2025 is given below: SI.No. Designation No. 1. Care Takers 59 2. Spare Care Takers 11 3. Care Health Workers 11 4. Emergency Staff 3 5. Co-ordinator 7 6. Head Co-ordinator 1 7. Supervisors 4 8. ....
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....her the appellant has received a sum of Rs. 7,02,76,146/- towards the expenses which is predominantly from CSR funds and if the trust registration is revoked then it creates a huge repercussion on the appellant trust and also on the doners. Hence it is prayed to your kind self to approve the recognition of the trust as a charitable trust under the section 12AB of the Act. 3. In addition to the above, the learned Counsel submitted that learned CIT(E) has wrongly rejected the application whereas the assessee has incurred expenditure as per its object mentioned in the trust deed. 4. On the other hand, learned DR relied on the Order of the lower authorities and submitted that huge expenditure has been incurred which is not commensurate as per the objectives of the trust deed and the AO and Range Head, after verifying the documents, have not recommended for the registration as per their observation which is incorporated in the CIT(E)'s Order and submitted that as per observation of the CIT(E), the institution is not eligible for registration under section 12AB of the Act. 5. After hearing both the sides and perusing the entire material available on records, we noted from the do....