2025 (9) TMI 1621

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....nesh Sheth, CA For the Respondent : Shri Ravi Kant Gupta, CIT-DR ORDER PER BIJAYANANDA PRUSETH, AM: This appeal emanates from the order dated 24.12.2024 passed by the Commissioner of Income-tax (Exemption), Ahmedabad [in short "CIT(E)"], wherein CIT(E) was rejected the application for approval u/s 80G(5)(iii) of the Act and provisional approval also cancelled. 2. The grounds of appe....

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.... 80G of the Act filed in Form No. 10AB. The CIT(E) issued three notices on 18.09.2024, 05.11.2024 and 09.12.2024, calling for various details. In response to the notices issued by the CIT(E), the assessee filed submission on 15.11.2024. He has discussed legal background of Rule 11AA(1), 11AA(2) and sections 2(15), 80G(5) along with Explanation - 3 and section 80G(5B). He subsequently issued a show....

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....e, institution or fund is expressed to be for the benefit of any particular religious community or caste; and assessee is not entitled for the benefit u/s 80G(5) of the Act. Hence, he rejected the application in Form 10AB and also cancelled the provisional approval. 4. Aggrieved by the order of CIT(E), the assessee filed appeal before this Tribunal. The learned Authorized Representative (ld. AR....

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.... the order of CIT(E). 6. We have heard both parties and perused the materials available on record. We have also perused the trust deed from where the objects of the trust clearly reveal that the fund was open for the education of the boys and girls of Shri Visha Shrimali Jain Samaj. The ld. AR submitted that an amendment was made in the trust to carry out charitable activities without discrimin....