TaxTMI 
TaxTMI 
2025 (12) TMI 1773
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....le vegetation, hoeing, cleaning, levelling, watering of plants, spreading of manure/fertilizer/soil conditioners, filling/re-filling of soil, application of pesticide/insecticide/anti-termite, trimming and/or shaping including cutting for the sake of avoiding damage to hedgers/trees, taking measures to ensure survival of the Plantation, removal and replacement of dead plants, supporting plant/tree with bamboo or arranging other supports including tree guards, and generally to do anything incidental, ancillary or subservient to the principal object of Plantation of Trees and Post-Plantation Maintenance. 3. The applicant has submitted that their main objects as contained in Trust Deed, contains: "Tree Plantation and Maintenance". Till date, the applicant has, under the common umbrella of "Sadhbhavna NGO", which inter alia includes Sadhbhavna Seva Foundation, planted and/or maintained 70 Lakhs trees. It includes, plantation and maintenance of trees, as part of tenders floated by various Municipal Corporations, and Highway Authorities. 4. The applicant, therefore, wants a ruling on the following questions: - 1. Whether, in the facts and circumstances of the case, the ent....
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....ial institutions and communities; necessity for encouraging the planting of trees alongside of roads, railway lines, rivers and streams and canals, and on other unutilized lands under State/Corporate, institutional or private ownership. Green belts should be raised in urban/industrial areas as well as in arid tracts for helping in checking erosion and desertification as well as improve the micro-climate." (d) The Government of Gujarat, for the purpose of Increasing the TREE COVER, has floated Harit Van Path Yojna on PPPs basis, whereby Tree Plantation is undertaken on sides of roads. Through an MOU entered into by the Government of Gujarat with Sadbhavna Vruddhashram - a Constituent of the applicant Trust, during Vibrant Gujarat Summit 2024, 40,000 plantations were envisioned from Dwarka to Somnath, on 50:50 PPP Basis - which has been successfully achieved. For the year 2025-26, the Government, has, under the Harit Van Path Yojna, envisioned 7,62,712 Trees to be planted and maintained, and the task is entrusted to Sadbhavna Vruddhashram-of Manav Seva Charitable Trust, on PPP Basis, with parking of Rs. 113.65 Crores, marking it to be a "special case". (e) The appli....
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....the same provisions under the GGST Act. 8. We have considered the submissions made by the applicant in their application for advance ruling as well as the submissions made both oral and written during the course of personal hearing. We have also considered the issue involved, the relevant facts & the applicant's submission/interpretation of law in respect of question on which the advance ruling is sought. 9. We find that the Government of Gujarat has floated "Harit Van Path Yojna" on PPP basis for increasing the Tree Cover by undertaking tree plantation on the sides of roads and vacant land. As per the Resolution No. FED/MSM/c-file/6/2025/1152/M Section dtd. 16.07.2025 issued by the Forests and Environment Department, Government of Gujarat, the applicant has been selected to plant 7,62,712 trees on PPP basis at Kutch/ Saurashtra as well as other districts along both sides of the road, coastal highways and other vacant lands. For the said work, the applicant would be paid as under: - SI. No. Year Scope of work Amount 1 2025-26 Planting of trees Rs. 1180 x 762712 = Rs. 90 crores 2 2026-27 1st year maintenance Rs. 224 x 762712 = Rs. 17.09 cror....
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....eless children; (B) physically or mentally abused and traumatized persons; (C) prisoners; or (D) persons over the age of 65 years residing in a rural area; (iv) preservation of environment including watershed, forests and wildlife; 11. Therefore, for being covered under the said entry, the following conditions have to be fulfilled: - (a) The entity should be registered under Section 12AA or 12AB of the Income Tax Act, 1961. (b) the services provided should fall under the definition of charitable activities as defined in the notification. 12. We find that the applicant has submitted a copy of the trust deed dtd. 14.03.2014. As per the trust deed, the objectives of the trust are mainly charitable activities extending to social activities, educational activities, health and medical related activities, cultural activities and spiritual activities. One of the activities mentioned under social activities at Sr. No. 11 is tree plantation activities. We also find that the applicant is registered with the Assistant Charity Commissioner, Rajkot having registration number E-9879 Rajkot. We, further, find that though the applicant in ....