TaxTMI 
TaxTMI 
2026 (1) TMI 184
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.... assessee. The order sheet reveals that the assessee has been represented by the AR, however except taking adjournments, no efforts has been made to argue the present Appeal. Therefore, we deem it fit to decide the present appeal on hearing the Ld. DR. 3. The Ld. DR vehemently submitted that the operations of the assessee do not cover under any of the limbs specified u/s 2(15) of the Act. Even the financing dominantly from 'Azcom Infosolutions' does not partake the character of income as envisaged in Sections 11 & 12 of the Act. Further submitted that objects/activities of the assessee are more of in the nature of the software development and start up consultancy that can't be accorded the visage of being charitable, therefore, the Ld. C....
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....n Kumar Sirohi, Director of the company attended this office and filed reply to queries cited above. After perusal of reply it is revealed that the applicant in its reply has stated that its main focus is on to initiate, nurture, support select initiatives of technology and business innovations and lend them to gain success with the high impact colleges, innovative products oriented research in select merging areas and standardization. One of the projects undertaken by the foundation i.e. "Digital Kisan", cited in support was for creating suitable organization to work at the grassroots with the farmers to educate them for adopting digital platform solutions and other agricultural services based emerging technology application for agricultur....
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....has not been used in that wide and extended sense, according to which every acquisition of further knowledge constitutes education. To that extent, the contention of the applicant of pursuing 'education' limb of section 2(15) is not acceptable. 8. Further the applicant has contended that such technology is the key catalyst will help to create an environment that will have well informed masses that in term will not only bring relief for poor but will ensure preservation of environment byenhancing the production through efficiency created by technology and y them to develop new technology. However, the applicant has not explained how the development of software fell under the limb relief for poor of section 2(15) of the Act n....
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.... Salary 24,00,000/- (68.4%) 42,00,000/- (77%) Car Lease 5,72,250/- (16.4%) 6,00,000/- (11%) Car Fuel 1,16,685/- (3.3%) 2,12,877/- (3.9%) Travelling Expenses 96,408/- 2,04,929- (3.8%) Business Promotion 68,551/- (2%) 55,783/- (1%) It is clear from the above that 92.8% of total expenditure in FY 2016-17 and 96.7% of fuel, travelling and business promotion that do not corroborate efforts made towards the stated claims. There is no expense that has been shown which could qualify as utilization for charitable purposes since its inception. It is further relevant to mention here that major expenditure incurred on salary is on account of payments made to Mr. Krishan Kumar only who is the Director ....
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....ly technologies, establish working relations between research faculty in technical institutions India and the industry in Indian and abroad". 9.3 It is another issue that returns of income for the A.Y 2016-17 and 2017-18 have been filed in Form No. ITR-6 that are required to be filed by the company other than a company income of which arise from any property for religious or charitablepurposes. It is pertinent to mention that as per rule 12(1) of the IT Rules, 1962, the returns of income of the society/trust/company which works on the principal of 'no profit no loss', are required to be filed in Form No. ITR-7. Filing of return of income in form no. ITR-6 clearly indicates that the applicant company is involved in business ....