2025 (9) TMI 1551

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....atta, CITDR ORDER PER PRADIP KUMAR CHOUBEY, JM: This is the appeal preferred by the assessee against order of Commissioner of Income Tax (Exemption)-Kolkata (hereinafter referred to as the Ld. CIT(A)] dated 31.07.2024 for AY 2023-24. 2. The only issue raised by the assessee in the various grounds of appeal is against the order of ld. CIT (E), Kolkata, refusing to grant approval of Sect....

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....tion clause although a resolution passed by the managing committee of the trust adopting the said clauses a copy of which was furnished before CIT(E) on a pain paper instead of affidavit and notarized stamp paper. The ld. CIT(E) observed that the irrevocability and resolution clauses are main clauses to ensure that the trust operate with a clear consistent purpose and provides structured approach ....

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....ted at all by the CIT(E) and the application for registration has been rejected on technical ground only. The assessee submitted the trust has been functioning regularly and has been carrying on its activities in accordance with the main objects which were never doubted. The ld. AR submitted that merely on the basis that the trust deed did not contain any dissolution or irrevocability clause, the ....

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....s available on record, we find that the trust has regularly functioning since its inception and pursuing its objects as prescribed in trust deed. The trust was registered vide registration no. 1482/67/8F 225 (86-87) dated 26.06.1989/ 04.07.1989. The Revenue has not either doubted the nature of activities carried on by the assessee trust nor any adverse remarks were ever drawn in the instant case. ....