2026 (2) TMI 353
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....rieved and has raised following grounds of appeal: 1. The learned Principal Commissioner of Income-tax (Central) (hereafter, "the Pr. CIT (Central)") erred in cancelling the registration of the Appellant under section 12AB(4). 2. The impugned order has been made without requisite jurisdiction or power, and in violation of the principles of natural justice, and therefore deserves to be quashed. 3. The Pr. CIT (Central) lacked the jurisdiction to pass the impugned order. 4. The proceedings leading to the impugned order, being admittedly initiated on the basis of a survey under section 133A, are void ab initio considering that the survey itself was illegal and without jurisdiction. 5. The Pr. CIT (Central) could not have relied on evidence collected in the course of the survey under section 133A as that survey was itself illegal. 6. The impugned order deserves to be quashed as it improves upon and goes well beyond the scope of the show cause notice dated December 15, 2022, by which the proceedings before the learned Pr. CIT (Central) were initiated. 7. The impugned order was passed in proceedings initiated without requisit....
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....t this appeal be allowed and that this Honourable Tribunal pass such other orders including orders as to costs as it thinks fit in the interests of justice. 3. Brief facts of the case shows that assessee is a trust incorporated on 1 July 2015 with following objects: - i. to provide scholarships, fellowships and awards for writers, authors and journalists involved in public interest or any other form of journalism that spreads information and awareness and benefits Indian citizens and India is a country. ii. to provide financial and other assistance to organisations and individuals creating and distributing public interest information to the public at large using digital media, social media, mass media or any other media thereby bringing about proper awareness and improving public understanding of issues iii. to promote excellence in education in the field of journalism by providing financial and other assistance to journalism schools and other educational institutes in the country iv. to create public interest content, achieve wider distribution and consumption of public interest content, provide services to support content creation and distri....
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....ust. xv. to publish books, periodicals, journals, bulletins, and newsletters for propagating all or any of the above-mentioned activities, without violating the provisions of section 11(4A) read with section 80G(5) of the income tax act, 1961 for such other similar provisions under any other law for the time being in force. xvi. to donate, assist and support persons or institution having similar objectives as this trust. 4. Thus, based on the above objects the assessee trust has been registered under section 12A of the Income Tax Act by the CIT (Exemption), Bangalore's as per certificate dated 8th of January 2016 with effect from assessment year 2016-17. This certificate of registration was subject to certain conditions that if the activities of the trust or institutions are found to be non-genuine or are not being carried out in accordance with the objects of the trust, its registration granted can become liable for revocation. 5. A survey under section 133(A) of the Act was conducted at the office of the assessee on 7 September 2022 by The Deputy Director of Income Tax (Investigation), Delhi based on authorisation issued by The Principal Director of In....
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....ion of the registration already granted to the assessee. 7. In response to the show cause notice, assessee asked for the material impounded during the survey which was provided to the assessee and further the assessee along with its representative and chief executive officer, senior program manager finance was intimated the information available. In paragraphs No. 1.6 of the order the learned CIT noted that during hearing, the assessee was made aware of the complete details of the evidence available on record which was relied upon for issuing show cause notice and the copies of which had already been made available to it. This included the addendum to the agreement with the Delhi Press Patra Prakashan Private Limited, chat of Shri Sunil Raj Shekhar (CEO) with various persons namely Mr Mohammad Sohail Mabarak (key person of Dool 360 private limited, Mr Vignesh Vellore (key person of Spunklane Media Private Limited), Mr Shekhar Gupta (one of the key person is of Print Line Media Private Limited) and Ms Barkha Dutt (a well-known journalist) along with details of the payments made to these persons and entities over the financial year 2017-18 to 2021-22, information regarding article....
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....ion analysed the reply of the assessee against each of the allegations in the show cause notice and gave finding vide page No. 15 of 73 to 63 of 73 of his order as under: 2.6 The assessee has also argued that specified violation in some instances cannot be used to cancel registration as a whole as it would be a disproportionate act. This argument of the assessee is also devoid of any merit as the provisions of Section 12AB of the Act are unambiguous and there isn't any concept of looking into the aspect of proportionality. Any specified violation can result in cancellation of the registration. 2.7 Considering above, the submissions of the assessee on each issue raised in the show cause notice are discussed as follows: 3.0 Exerting influence for promotion of political articles by paying more money viz-a-viz other articles: In the show cause the assessee was confronted with the aspect that it was involved in promoting political articles by paying more premium for such articles viz-a-viz other articles and exerting control on the category of content being published. In response to the same, vide reply furnished on 22.12.2022, the assessee had su....
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....ell before the delivery. f) The Foundation makes no intervention whatsoever in the editorial decisions of grantees its support. The stories are based on the editorial decisions, and not based on any ideology or political stance." 3.1 Copy of the rate card made available by the assessee is reproduced as follows: 3.3 Since this was against the independence of the entity to whom grant was being paid and it also appeared from such agreement that IPSMF was trying to control the category of the content, the assessee was again confronted with this addendum to the agreement during hearing on 11.01.2023. In response to the same the assessee made following submissions vide reply dt. 12.01.2023: "IPSMF Response: The Content Commissioning Contractual Rate Card-Annexure 5 From the attached rate card it is clear that there are Six broad categories of Story Types against each of which a Story Format and a Minimum and Maximum rate is specified. The rates for English publications are comparatively higher than Language publications due to their higher input costs. Also, the market reality is that, in general, English language journalism pays more....
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....th the rate card is at Annexure 8" 3.4 Vide letters dt. 09.02.2023 and 17.02.2023 the assessee submitted as follows: "26. We place before you, copies of the Agreements with Delhi Press Patra Prakashan Pvt Ltd, publishers of The Caravan. The Master Content Commissioning Agreement dated June 15, 2018 is enclosed at Annexure 6 and the following Addendum agreements (enclosed as Annexures ) entered into with the Company with specific reference to the broad content plan that the online edition of The Caravan magazine is expected to produce in the public interest. Term 1-Addendum-1-June 15, 2018-Content plan on page 7 is at Annexure 6.1 Term 2-Addendum-2-October 14, 2019-Content plan on page 6 is at Annexure 6.2 Term 3-Addendum-3- November 14, 2020-Content plan on page 6 is at Annexure 6.3 Term 4- Addendum-4-February 22, 2022-Content plan on page 6 is at Annexure 6.4 27. IPSMF Funds only content meant for the online edition www.caravanmagazine.in. We clarify that the stories appearing in the print magazine, The Caravan, are not funded by IPSMF. IPSMF's rationale for funding the online edition of Caravan a....
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....and communities. 5 Agriculture, Water, Rural Issues, Environment Agrarian issues, Farmer distress, Policy and efficacy of schemes, Animal husbandry, Issues in availability of water and its management, River waters management, Climate change, Energy policy, Pollution, and Land use. 6 Security, Diplomacy and strategic affairs Foreign policy, India & its neighbourhood, Relations with Pakistan, India's geo-political environment, Relations with great powers, US & China as a factor in India's policy and diplomacy, Effects of domestic politics on foreign policy. 7 Education and Livelihood The national education policy, Public vs. private education system, Condition of the state education infrastructure, Jobs & employment, Effects of industry 4.0 & technology on job creation. 8 Public Health, Healthcare, Covid-19 etc. Public health, Medical infrastructure, Health policies, Pharma etc. 9 Books, Indian History, Art & Culture Books, Indian History, Art and Culture. " 3.5 The submissions of the assessee have duly been considered. A perusal of the initial response of the assessee as made on 22.12.2022 showed that it had clai....
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.... above schedule shows that the payment is on basis of cost per story (although required to be comprehensive) whereas the normal rate card shows the word length or time duration as the only basis for various broad categories. The assessee has tried to justify its action by claiming that 'Caravan' published by DPPPPL is a highly rated magazine which has won several awards. The issue here is not that of the quality of the content of the magazine but the fact that the assessee is promoting printing of political articles and trying to control the category of content published by paying differential rates. This clearly goes against the stated objectives of the trust. So although the normal rate card has been printed to show that it is meeting the objectives of the society but in the back ground it is entering into agreements to meet its political agenda by paying at higher rates for political articles by different media. This clearly shows that the actions of the assessee are in sharp violation to the objects of the trust as early as in June, 2018 (FY 2018-19) i.e the date of above agreement. The same is a specified violation as per Explanation (a) and (e) to Section 12AB(4) of t....
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....uts on Whatsapp and had asked the concerned persons to take up particular kind of stories. Some of such chats are as follows: * Chat of Mr Sunil Rajshekhar with Mr Muhammed Suhail Mabrak: Mr Muhammed Suhail Mabrak is one of the Key Person of Dool 360 Private Limited. Dool 360 Private Limited had received the following grants from IPSMF: Dool 360 Private Limited FY Grant received 2017-18 27,56,849 2018-19 71,91,121 2019-20 69,99,924 2020-21 40,00,000 Total Grant received 2,09,47,894 In the Chat between Mr Muhammed Suhail Mabrak and Mr. Sunil Rajshekhar, Mr Sunil Rajshekhar had given some links to Suhail and, in return, Mr. Suhail had replied affirmatively to take up the matter. This does not appear to be a genuine activity as it was a targeted news. The relevant part of chat is being reproduced as follows: * Chat between Mr Vignesh Vellore (Key person of Spunklane Media Pvt Ltd) and Mr Sunil Rajshekhar: In the Chat between Mr Vignesh Vellore (Key person of Spunklane Media Pvt Ltd) and Mr Sunil Rajshekhar, it is observed that Mr Sunil Rajshekhar is giving inputs....
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....ain articles/issues, during hearing on 11.01.2023 the assessee was confronted with the chats between its CEO and other media entities being supported by it. In response to the same the assessee made following submissions vide reply dt. 12.01.2023: "The Survey Team had accessed the Whatsapp Chat of CEO Sunil Rajshekhar with a few of the grantees. From the chats it is implied that these grantees/content providers are being influenced to write particular kind of stories. IPSMF Response: IPSMF is not privy to the Survey report. Hence it is extremely difficult for us to understand the context under which the said chats are being quoted. We request you to share a copy of the Survey report, after which we will require at least a week's time to analyse the relevant chats as it will requires us to also talk to the parties involved to ascertain the exact context of the Chat some of which have happened years ago. Nevertheless, we have endeavoured to make a preliminary analysis of the Chats that you brought to our attention. On receipt of the Survey Report, we should be in a position to offer to you a more comprehensive and contextual response that what ....
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....development for journalists and journalism. The Founder of Content Provider The Lede had impleaded in a case to assist the High Court in a grave matter were some persons were claiming to be Press Reporters and indulging in Criminal activities. These were allegedly fake journalists working for fake publications. The story was forwarded to Mr Vignesh Vellore of The News Minute (TNM) which also covers Tamil Nadu with a suggestion that it may interest readers of The News Minute. In this case there was no response from Mr Vignesh Vellore. It may be assumed that it did not interest readers of TNM. There was no question of influencing Vignesh Vellore and TNM to publish the story as much as it has been the Foundation's practice of encouraging grantees to share their stories for a wider audience reach in line with the Objectives spelt out in the IPSMF Trust deed. c. Chat with Shekhar Gupta of The Printline Media Pyt Limited-The Print Chat on 9 October 2020-CLAT issues. Please provide clear copy of the chat. IPSMF Response: A clear copy of chat is at Annexure 9c In this case a 'news source' who happened to know Mr Sun....
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....oring was done. This makes it clear that there was no exercise of control." 4.3 Vide reply dt. 09.02.2023, the assessee has further submitted as follows: "40. On the point of the CEO Sunil Rajshekhar attempting to influence four journalists, Shekhar Gupta of The Print, Barkha Dutt of Mojo Story, Vignesh Vellore of The News Minute and Mohammed Suhail of Dool News, into carrying stories thereby implying a hold on them, the assessee has clarified in its submissions dated January 12, 2023 and January 13, 2023 with contextual explanations on each of the 4 instances. The CEO, Sunil Rajshekhar, has also submitted an affidavit stating that the purpose of the conversations in no way related to the action of exerting the least bit of pressure on any of the grantees/content providers. 41. The Foundation had approached the above mentioned founders of the 4 entities for their understanding of the WhatsApp chat conversations. From their response, it is clear that none of them have interpreted the conversations in the manner in which the department has sought to insinuate. Each of them have pointed out that: a. they had not followed up on the suggestions made a....
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....etter as in the link, is just a make believe story, far from truth. 4.6 In relation to chat with Vignesh Vellore of Spunklane Media Pvt Limited, the assessee has tried to explain it by submitting that its CEO had merely forwarded the story to Mr Vignesh Vellore of The News Minute (TNM) which also covers Tamil Nadu with a suggestion that it may interest readers of The News Minute. The assessee has submitted that there was no response from Mr Vignesh Vellore and so it may be assumed that it did not interest readers of TNM. However, these arguments of the assessee are once again found to be very generic. The issue is that of the assessee trying to influence the grantee to take up a particular issue. Whether the same is actually taken up or not is secondary. The chats do show that the assessee was trying to influence its grantees regarding what news to take up, if they wanted the grants to continue. So the argument of the assessee that it had merely forwarded the information, is just a make believe story, far from truth. 4.7 In relation to chat with Mr Shekhar Gupta of The Printline Media Pvt Limited, the assessee has tried to explain it by submitting that its CEO had....
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....ng controlled by the assessee and the grantees could not say 'NO' to it. So the argument of the assessee that it had just passed the information which complemented her work, is just a make believe story, far from truth. 4.9 Although in its submissions the assessee has relied upon an affidavit of the CEO and letters from the grantees to support its contention that it had not tried to influence the grantees and that the grantees were not influenced, however the same are just unsubstantiated self-serving documents, which cannot be relied upon. 4.10 The above discussion leads to the conclusion that the assessee was actively involved in influencing various grantees for publication of particular kind of stories/articles which were chosen by assessee trust and were of interest to assessee trust. This is not as per its objects. The same is a specified violation as per Explanation (a) and (e) to Section 12AB(4) of the Act. The chats relate to previous years 2019-20, 2020-21 and 2021-22. The grants given to these persons relate to previous years 2017-18 to 2021-22. In view of the above specific instances this can be concluded that the assessee had always been influe....
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....ould like to emphatically state a) That it is inherently and foundationally against any polarization or incitement or bigotry in whatever form, especially in any story costed to the Foundation. b) For the Assessee's trustees, renowned for their achievements and unimpeachable integrity, these are articles of faith and deeply held convictions and any suggestion to the contrary is repugnant-a quest for syncretic society, democratic values and harmony-the values that the Constitution of India enshrines and are foundational values for the Indian Republic. c) Therefore, any story or content that is antithetical to these values is rigorously reviewed and turned down. d) Conversely, the job of the media and journalism is to red-flag any attempt to incite, abet or polarize, to the extent that the story is based on facts. e) Journalism, by its very nature, is anti-incumbent, if not adversarial. This is a character of the media all over the world. To bring out the dissonance between promises and delivery, expose corruption, bring out instances of discrimination based on religion, caste, language, etc.- anything that is ultra vires of the Consti....
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....w-database-reveals-rise-in-sedition-cases-in-the-modi-era IPSMF Comments: * The database which took six months to collate is based on a database of the government's own statistics, from databases like the district court portal, state police websites, data from high courts; and law-centric websites like such as India Kanoon, SCC Online and Manupatra. * Therefore, it is i) fact-based, ii) from official/ government/ court data. * Article 14 has only collated and given it a shape-the data speaks for itself. 3. No Evidence, No crime, Muslim Man arrested for selling shoes https://www.youtube.com/watch?v=Nh8Qslwh08U&feature=youtube IPSMF comments: * The story highlights how what would have been a miscarriage of justice was stopped in time. * The story talks to both sides. * It also underlines that the police, after ascertaining the facts, dropped section 153A- Promoting enmity between different groups-from the FIR. * This is public interest journalism as it red flags a probable miscarriage of justice against a citizen, points out wanton vigilantism which may have adverse public consequences. ....
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....stance where public monies were spent to generate a public good. * This was pointed out by none other than India's Chief Information Commissioner (CIC) at that time, Mr Y K Sinha, who called the ICMR's refusal to provide government's funding date on Bharath Biotech "evasive and untenable". * Therefore, the story was in complete public interest and relevant at a time of the pandemic when it was important for the media to hold any government to account. 7. Sedition database-a decade of lawlessness https://article-14.com/post/a-decade-of-darkness-our-new-database-reveals-how-a-law-discarded-by-most-democracies-is-misused-in-india-61fcb8768d15c IPSMF Comments : * The database is based on extensive research. * It went through 1,300 legal documents, 800 media reports, 125 first information reports (FIRs) and more than 70 interviews with those accused of sedition, D. Janjwar Foundation-funded Janjwar.com 8. लोनी के अल्पसंख्यकों का आरोप, यूपी....
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....325;ार नहीं मांग रही कोई कागज, 'कागज नहीं दिखाएंगे' के नारे के कारण आंदोलनकारियों में फैल रहा भारी भ्रम https://janjwar.com/post/what-is-the-reality-of-kagaj-nahi-dikhayenge-munish-kumar IPSMF Comments; * This is an opinion piece, akin to a column in print. * While there are grave charges voiced against the government on the issues of CAA and NPR, they are not personal or amount to libel. * It is more in the nature of making a political point which is in line with the format of an opinion piece. 11. जनज्वार इम्पैक्ट : अंबेडकर-ब....
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....as follows: Headline of the article Weblink of the article Theme of the article Our new database reveals rise in sedition cases in the Modi Era https://www.article-14.com/post/our-new-database-reveals-rise-in-sedition-cases-in-the-modi-era Sedition law Tortured, Harassed, Accused of Terror- Framed for being Muslim in India https://twitter.com/Article14live/status/1413322849859694593?s=20 Miscarriage of Justice No evidence no crime: Muslim man arrested for selling shoes https://twitter.com/Article14live/status/1347386945979248647?s=20 Miscarriage of Justice for Muslim Why Kashmiri journalist Sajad Gul faces police cases for doing his job https://www.article-14.com/post/why-kashmiri-journalist-sajad-gul-faces-police-cases-or-doing-his-job- 61cbcde7784b6 Censorship & False Cases As BJP talks up law against conversions, attacks against Christians rise in Karnataka https://www.article-14.com/post/as-bjp-talks-up-law-against-conversions-attacks-against-christians-rise-in-karnataka--61b1cdd011061 Legislation Sedition Database: A Decade of Darkness https://sedition.article-14.com/ Sedition law 5.3 Janjwar Foundation ha....
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....2354;ितों पर लाठी-डंडों से हमला मामले में 8 आरोपियों को जेल Story URL: https://janjwar.com/post/janjwar-impact-8-accused-sent-to-jail-for-assault-with- sticks-on-dalits-in-kanpur-dehat-manish-dubey 500 रुपए लेकर धरना देने के आरोप पर शाहीन बाग की महिलाओं ने दिया जवाब Text URL: https://janjwar.com/post/caa-womens-protest-continues-in-delhis-shaheenbagh-for-last-13-days 5.4 A perusal of these articles show that most of them try to impress about excesses on a particular community in a way to sensationalize the matter with the motive of polarization of the society. In its reply the assessee has tried to justify each of su....
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....he objects of the trust. In his statement recorded on 07.09.2022, Sh Aditya N S had clearly stated that before agreeing to give grant to any grantee the contents published on its website are evaluated. So while entering into agreement with these entities the assessee trust was well aware of the nature of contents being published by them. As such there were specified violations as per Explanation (a) and (e) to Section 12AB(4) of the Act. The grants were given during previous year 2021-22. 6.0 Grants to profit making entities in form of professional fees: In his statement, Mr. Sunil Rajshekhar had admitted that funds received by assessee trust had been utilized for giving grant to 'not for profit' organisation and as 'content commissioning charges' to commercial organization as 'professional fee'. Relevant part of his statement recorded under Section 131(1A) of the Income-tax Act on 07.09.2022, is reproduced as follows: Q. 17 Please give the details of the application of fund received by M/s Independent and Public-Spirited Media Foundation. How do you utilise the fund received from Donor? Ans. Sir, Fund is majorly used for online....
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....axMaharashtra Media Solutions LLP ABEFM7926N 12,45,000 77,39,998 29,09,000 45,92,000 18. Printline Media Pvt Lid AAICP7988B 1,14,20,000 1,93,62,003 1,88,68,000 84,45,000 19. Spunklane Media Pvt Ltd AAWCS2326J 10,25,000 53,74,998 90,15,006 9,85,005 46,08,000 20. Vikara Media Pvt Ltd AAFCV0080M 79,04,259 99,69,799 78,19,436 21. Yonika Infotainment Private Limited AABCY0847P 35,92,999 21,35,500 26,57,000 Grand Total 2,49,85,318 3,11,03,104 7,23,99,581 11,55,86,959 9,74,33,501 8,12,00,998 6.2 On being confronted with this issue, vide reply filed on 22.12.2022, the assessee submitted as follows: "34. All these assertions are denied. The Assessee submits that it is incorrect to state that the CCA (service agreements as described in the SCN) contain no details of the services to be rendered. The relevant extracts of the trust deed are reproduced below: 4.4 To create public interest content, achieve wider distribution and....
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..../private commercial entities not falling within the prohibited category of persons specified u/s 13(3) to avail the services for achieving the purpose of charitable object does not militate against the charitable nature of the organisation and to deny exemption u/s 11 or withdraw registration us 12AA(3) of the IT Act. We find the Delhi Bench of the Tribunal in the case of R.B. Seth Jessa Ram Charitable Hospital (supra) has upheld the order of the CIT(A) directing the Assessing Officer to allow exemption u/s 11 of the Act under somewhat similar circumstances." 6.3 Vide reply dt. 12.01.2023, the assessee made following submissions: "E. Grants to profit making entities in form of professional fees About Rs. 46Cr up to March 31, 2022 has been paid through CCA. There were no services rendered, but the fees were paid. Money was just transferred to these 21 entities. The money spent on these entities cannot be considered as application of funds. IPSMF Response: The IPSMF trust was set-up with an objective of promoting public interest journalism in India and enable dissemination of public interest information through digital media, mass media, s....
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....CA is an expenditure (and not grant made by the IPSMF) incurred by IPSMF in furtherance of its objects and accordingly qualifies as a valid application of income under the provisions of Section 11 of Income Tax Act, 1961 ("the Act"). We had also stated in paragraph 2 of our written submissions filed on 22.12.22 that the proposed action is wholly disproportionate. Even if the allegations are correct (no concession made) cancellation of registration is not permissible in law and will be wholly disproportionate as the allegations touch upon a minuscule portion of the expenditure. Please see the decision of the Bombay High Court in CIT vs. Manekji Mota Charitable Trust (2019) 109 taxmann.com 258 and the order of the Supreme Court dismissing the departmental SLP reported in 120 taxmann.com 58. In this case the trust had spent 71% of the gross receipt as per its objects and 21% had been spent on religious purposes. Registration was denied on this ground. The High Court held in favour of the assessee holding that these are matters to be examined at the time of assessment and cannot justify denial of registration. The two case laws are attached as Annexure 10 We would als....
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.... their web portal. 7. The agreement did not list any specific service to be provided by the service provider. 8. The agreement with not-profit making entities who were given grants does not appear to be very different from agreement with profit making entities for content commissioning. 6.5 Agreement entered between assessee trust and Atvi Infotainment Pvt Ltd impounded during the course of survey shows that assessee trust engaged Atvi Infotainment Pvt Ltd (content provider) to provide some services in accordance with agreement or any addendum to the agreement. However, neither the agreement nor the addendum details any specific services to be provided by content provider to the assessee trust. Thus, the expenses booked by assessee trust as professional fees for the above services remains shrouded. Relevant part of the agreement is as follows: 2. CONTENT COMMISSIONING & TERM 2 1 CONTENT COMMISSIONING [a] Pursuant to an Application made by the Content Provider, IPSMF may engage the Content Provider to provide the Services, and the Content Provider accepts such engagement to provide the Services, in accordance with this Agreement ....
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....service having been rendered to assessee trust. The publishing of various articles/stories by these entities was their normal business practice and it was not for the purpose of rendering any service to the assessee. The content of the stories was not owned by assessee trust. Further, assessee trust does not have any portal where such stories could be published. Thus, it can be seen that assessee trust was making payments in form of professional fee to these profit-making entities without any actual delivery of service to it. Such expenditure cannot be regarded as application of its. income. 6.7 As regards the argument of the assessee that the professional fee could be considered as grant, the same also deserves to be rejected. This is for the reason that the payments have specifically been indicated for getting some services and not as grants. Since the assessee has not been able to provide the details of the services rendered by the said entities, evidently for the reason that no such services were ever rendered, during proceedings under consideration it has given an alternative argument that the said payments could be considered as grants to profit making entities as th....
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....t the assessee trust had granted funds to Pravda Media Foundation (Alt News) during the FY 2019-20 to FY 2021-22 to the tune of Rs. 2.25 Cr. It is pertinent to mention that Co-founder of Alt News Mr Mohammed Zubair is under investigation by multiple agencies for the hurting religious sentiments through his twitter posts. The grant was required to be released only on the fulfilment of certain conditions as enshrined in the agreement viz number of stories, audience reach, external funding raised by the organization as per the agreement. However, the impounded documents show that organization was being supported based on availability of funds and cash reserves with the grantee viz Alt News. The relevant portion of the statement is produced below: 7.1 On perusal of an internal email dated 25-04-2022 from Mr. Avinash to Mr. Sunil Rajshekhar of assessee trust it is observed that assessee trust had released certain grants to Alt News in the background of Alt News being involved in reporting of matters related to farmer's protest, covid-19, Delhi riots, CAA-NRC protests, Jamila milia incidents and others. Such coverage has been given the colour of fact checking. The relevant p....
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....a number of sites, even general news sites, to begin their own efforts to integrate fact-checking as a significant part of their offerings. i) Other than Alt News and YouTurn, recipients like East Mojo, Max Maharashtra, The News Minute, The Print and The Wire have regular and established fact- checking sections. This is important to keep journalism and the social media honest so that fake news and disinformation is not amplified and create discord and harmony." 7.3 Vide reply dt. 12.01.2023, the assessee submitted as follows: "F. Targeted Covering in the garb of fact checking: Granted funds to Pravda News-AltNews-Mr. Md. Zubair is being investigated for hurting religious sentiments through his twitter posts. a. From Aditya's recorded statement-the following Board note on AltNews as discussed during the 42nd Board meeting, dated May 07, 2022 was noted: "The Board was informed that while Alt News had informally placed a request for 4th Term grant renewal to support its Bangla and Kannada editions, it had not submitted any details to the Foundation. However, as Alt News' financials are currently in a comfortable zo....
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.... 25/04/2022 from Avinash to Sunil Rajshekhar : Full Note at Annexure 11 This note prepared jointly by the IPSMF operating team on Alt News having completed the grant-cycle of 3 years was forwarded by Program Manager Avinash Hukkeri to CEO Sunil Rajshekhar. a. It is a fact that there was a fair amount of misinformation and disinformation that was floating on Social media around events like Farmers's protests. Covid 19, Delhi Riots etc. The above para states that Alt News was prompt in tackling issues of misinformation. Some of the issues were amplified greatly on Social media and required to be corrected. Alt News did a commendable job on this front. b. Alt News was Founded by Pratik Sinha and Zubair is Co-founder. The venture operates out of Ahmedabad." 7.4 A perusal of the above shows that the assessee has tried to skirt away the issue of funding by referring it to its policy of making exception. Further, it has remained silent on the issue of pending investigations against Mr Mohammed Zubair, the Co-founder of Alt News. A perusal of the details discussed as above clearly bring out that exception in funding was being given as the en....
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....fect from previous year 2016-17 and for all subsequent previous years as per provisions of section 12AB(4) of the Act. Accordingly, the impugned order was passed on 26th of June 2023. Submission on behalf of appellant 14. The assessee is aggrieved with that order and is in appeal before us. Shri A Sheshadri, Chartered Accountant and Shree Bharadwaj Sheshadri, Advocate, the learned authorised representatives, appeared and submitted the detailed argument. The assessee filed two volumes of the paper book containing 929 pages. The assessee in the paper book has also placed six videos (not shown to us). Assessee also submitted the list of donors [General Donors and corpus donors] from AY 2016-17 to 2025-26 to show that most illustrious donors have donated the funds for the object of the trust. Assessee also submitted a supplementary paper book containing 166 pages to support which shows methodology and the process by which the funds of the trusts are utilised. It contains some report, management Information systems report, email correspondence, agenda for board meetings., legal due diligence reports etc. On completion of hearing, assessee also submitted details by email dated 25-1....
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....oordinate bench in SHRI MOHAMMAD ABDUL NAJIB V THE DCIT CENTRAL CIRCLE BELLARI [ITA NO. 1175/BANGALORE/2024 FOR ASSESSMENT YEAR 2012-13] wherein it has been mentioned that the transfer orders if made without jurisdiction, can be quashed and further the consequent orders are also quashed. He also referred to the decision of the coordinate bench in case of CAPSTONE SECURITIES ANALYSIS (P) LIMITED V DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 1 (1), PUNE [2017] 85 TAXMANN.COM 270 [PUNE] wherein it is held that when the case was transferred from Mumbai to Pune but PAN of the assessee was still lying with the ITO Mumbai, is held to be unjustified. 19. He further stated that CIT Central could not have jurisdiction to cancel the registration already granted to the assessee. He placed reliance on PACIFIC ACADEMY OF HIGHER EDUCATION & RESEARCH SOCIETY V PCIT [ ITA NO 4 & 5/JODH /2020 DATED 25/01/2023. He submits that such power only vests with the CIT [Exemptions] who granted it. The power of cancellation did not transfer to PCIT [Central] by passing order u/s 127 which also does not contain any reference to transfer of powers of cancellation. 20. He further referred to the definition o....
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....coming to the various observation made by the learned CIT in his order, He referred to the various answers given by the assessee and relied upon them. Regarding the issue of payment of Higher charges to some articles as per rates card, the Ld AR referred to the page no 192 of the paper book where in assessee has placed Master Content Commissioning Agreement dated 15/6/2018 between assessee and Delhi Press Prakashan Private Limited. He referred to page no 195 of the of the paper book referring to para no 2.1 & 2.2 of the agreement. He also referred to the addendum to this agreement placed at page no 220-221 which is an addendum to that agreement dated 15/6/2018 and page no 226 where the rates were similar. He submitted that allegation of the ld. CIT that assessee is paying higher for some articles than other is incorrect. 26. It was also the argument that the learned CIT at the time of issue of the show cause notice, the ld PCIT did not reach at the specific finding that what are the 'specified violations' conducted by the assessee and therefore his notice was so routine in general, thus, he did not invoke jurisdiction correctly by issuing the show cause notice. The asses....
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....on order passed under section 12AB of the Act. He submitted that that the findings given therein clearly shows that the assessee's objects and activities are different and therefore the cancellation order passed by the learned CIT is sustainable, valid in law, with jurisdiction. The learned departmental representative further relied upon the written submission made during the hearing earlier carried out on 10 January 2024 containing the arguments of the revenue on the jurisdiction of the learned PCIT in passing the order and further the evidence collected during the course of survey. He further referred to notification dated 22/10/2014 as well as the record of survey proceedings. Decision & Reasons 32. We have carefully considered the rival contention and perused the orders of the learned lower authorities. We have also carefully perused paper books filed, judicial decisions relied upon. 33. No arguments were advanced on Ground no 1 and 2 of the Appeals, stated that these are general, Hence, dismissed. 34. Ground No.3 of the appeal is that the Principal CIT lacked Jurisdiction to pass the impugned order. The Assessee challenges that order passed u/s 127 (2) of the A....
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....portunity of being heard in the matter, ^73wherever it is possible to do so, and after recording his reasons for doing so, pass the order; (b) where the ^74[Principal Directors General or] Directors General or ^74[Principal Chief Commissioners or] Chief Commissioners or ^74[Principal Commissioners or] Commissioners aforesaid are not in agreement, the order transferring the case may, similarly, be passed by the Board or any such ^74[Principal Director General or] Director General or ^74[Principal Chief Commissioner or] Chief Commissioner or ^74[Principal Commissioner or] Commissioner as the Board may, by notification in the Official Gazette, authorise in this behalf. (3) Nothing in sub-section (1) or sub-section (2) shall be deemed to require any such opportunity to be given where the transfer is from any Assessing Officer or Assessing Officers (whether with or without concurrent jurisdiction) to any other Assessing Officer or Assessing Officers (whether with or without concurrent jurisdiction) and the offices of all such officers are situated in the same city, locality or place. (4) The transfer of a case under sub-section (1) or sub-section (2) may be made ....
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....alt with. Thus, the order itself is a non-speaking order. The basic and minimal requirement of the petitioner being given a personal hearing and the opportunity to respond to the proposed transfer is to enable the authority to consider whether in the facts and circumstances of the case, the transfer of the case from Mumbai to Aurangabad is warranted. Particularly, bearing in mind that the petitioner has otherwise no connection with Aurangabad except for having sold 3 out of 78 flats in the building being constructed to the persons who are being assessed at Aurangabad. Thus, we do not find any similarity in those cases where the case of the assessee is in the same city i.e., Bangalore. Thus, there is no inconvenience faced by the assessee shown to us. It is also not the case that case of the assessee is tagged with another assessee. Case of the assessee is transferred independently and not connected with any other assessee and also transferred in the same city. Thus, reliance on the decision of Honourable Bombay High Court does not help the case of the assessee. 38. The second issue raised by the ld AR is that transfer of case u/s 127 of the Act is only with regard to assessment ....
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....erchant Association in Wholesales Cloths Merchants Association v. Pr. CIT [IT Appeal No. 688 (JP) of 2019, dated 6-1-2021]; Jhodpur ITAT Bench order in the case of Pacific Academy of Higher Education and Research Society v. Pr. CIT (Central) [IT Appeal No. 04(JODH) of 2020, dated 25-1- 2023] and Gyan Sagar Education & Charitable Trust v. Asstt. CIT [IT Appeal No. 6054 (Delhi) of 2018, dated 3-9-2020]. The ld AR emphasized that transfer of jurisdiction u/s 127 is made for granting rights to the AO to assess the income of the Trust and it does not grant power to grant/cancel registration to the PCIT(Central). The ld. counsel for the assessee prayed that the order of the PCIT(C) cancelling registration u/s 12A, devoid of valid jurisdiction, needs to be set aside. 40. That decision further held in para no 33 as under: - 33. A reading of clause(b) of the Notification 70/2014(supra) conjointly with the Explanation of section 127 leaves no room for doubt as to the intention of the Legislature as to the jurisdiction to be exercised by the authorities concerned over a class of case once order u/s 127 is issued. In the instant case, once the order u/s 127(2) dated 01.12.2016 was ....
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.... persons, which were assigned to AO subordinate to him, under section 127 of the Act. We are thus of the considered and firm view that a harmonious and constructive interpretation of Notification no. 70/2014 and the CBDT directive dated 19.01.2024 would show that the Pr.CIT(Central) assumes the power and indeed obligated to perform all the functions as stipulated in the Act, over the assessee once an order u/s 127 is issued transferring the jurisdiction to AOs subordinate to him. 41. Thus, it is evident that decision cited by the ld AR Agarwal Vidhya Pracharani Sabha V PCIT is distinguishable, and the facts stated in the paragraph 33 of this Advantage decision is identical. 42. Further on careful reading of section 127 of the Act and explanation there to that the word ' case' does not restrict it to any "Assessment year" but uses the phrase ' Year'. Had it been the intention of the legislature to restrict it to any " assessment Year' it would not have used the word 'year'. Principles of Interpretation provides that an unambiguous and plain statute must be given its full interpretation. 43. Even otherwise the order of the ld PCIT is canc....
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....iction over a case entail not only 'assessment' process but there are several functions and powers assigned to the jurisdictional hierarchy over that case. For example, the assessment is made by the ACIT/ITO, but when coercive action for recovery of demand is to made, the ACIT/ITO has to take approval from the Pr.CIT (Central). Similarly, where the AO denies stay of demand in a case, the Pr.CIT (Central) can review the decision of the ACIT/ITO. There are numerous such examples where the powers and functions over a 'case' has to be exercised in a chain of command in the hierarchy of Pr.CIT (Central).Similarly, a CIT(Exemptions) has powers/functions over Ranges which are manned by the Additional CIT/Joint CITs. There are four/five assessing officers in rank of ACITs/ITOs in a Range and all of them exercise their powers/functions under the CIT(Exemptions). Any jurisdiction over a 'case' cannot be segregated between two different PCIT/CIT that is to say that PCIT(C) will conduct 'assessment' proceedings and the PCIT(E) will conduct registration/cancellation. Such an interpretation will make the exercise of transfer of jurisdiction over a 'case' u....
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....2) of section 120 of the Income-tax Act, 1961 (43 of 1961) and in supersession of the notification of the Government of India, Central Board of Direct Taxes number S.O.822(E), dated the 23rd August, 2001 published in the Gazette of India, Extraordinary, Part II, section 3, sub-section (ii), dated the 23rd August, 2001, except as respects things done or omitted to be done before such supersession, the Central Board of Direct Taxes hereby,- (a) directs that the Director General of Income-tax or the Chief Commissioner of Income-tax specified in column (2) of the Schedule -1 or II annexed to this notification, as the case may be (hereinafter referred to as the "said Schedules") or the Principal Commissioner/Commissioner of Income-tax specified in column (4) of the said Schedules or Joint Commissioners of Income-tax or Assessing Officers, shall continue to exercise powers and perform the functions as stipulated in the said Act, in respect of such persons or classes of persons or such incomes or classes of incomes or such cases or classes of cases in which the said Income-tax authorities have been exercising powers and performing the functions on the basis of jurisdiction assigned ....
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....C), (23F), (23FA), (24), (46) and (47) of section 10, section 11, section 12, section 13A and section 13B of the Income-tax Act, 1961 and assessed or assessable by an Income-tax authority at serial numbers 88 to 111 specified in the notification of Government of India bearing number S.O. 2752 dated the 22nd October, 2014". 46. On the issue of the decision of Honourable Supreme Court in Principal Commissioner of Income-tax vs. ABC Papers Ltd. [2022] 141 taxmann.com 332 (SC)/[2022] 289 Taxman 150 (SC)/[2022] 447 ITR 1 (SC) [18-08-2022] we find that the question before the honourable court was the jurisdiction of the High Court consequent upon administrative order of transfer of a 'case' under section 127 of the Act from one Assessing Authority to another Assessing Officer located in a different State. Honourable Punjab & Haryana High Court took the view that such a transfer would not change the principle laid down in Seth Banarasi Dass Gupta. However, the Honourable Delhi High Court in CIT v. Sahara India Financial Corpn. Ltd. [2007] 162 Taxman 357/294 ITR 363 and CIT v. Aar Bee Industries [2013] 36 taxmann.com 308/357 ITR 542 has taken a different view. The Honourable Del....
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....ion of the Amla Jyothi [ supra]. We find that decision of Delhi ITAT in Advantage India [ Supra] has considered this aspect in para no. 48 onwards as under:- "48. On the issue of the jurisdiction of the Pr. CIT(Central-2), Delhi to cancel the registration with retrospective effect, we find that the express power of cancellation were duly incorporated by the Parliament into the Income Tax Act, 1961 by way of Finance Act, 2004 vide which a specific section 12AA(3) was incorporated in the statute. Further, vide Finance Act, 2010, Section 12AA(3) was amended to include cancellation of registration granted u/s 12A. The legal dictum is that the retrospective applicability can either be expressly provided for or can be inferred by necessary implication from the language employed. The Hon'ble Supreme Court in the case of Zile Singh v. State of Haryana (2004) 8 SCC 1 at Para 15, held as follows: "It is not necessary that an express provision be made to make a statute retrospective and the presumption against retrospectivity may be rebutted by necessary implication especially in a case where the new law is made to cure an acknowledged evil for the benefit of the communi....
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....ro Lab v. ITO (2019) 102 taxmann.com 225 (Madras). **** 88. As regards reliance placed on the judgment of Madras High Court in the case of Prathyusha Educational Trust (supra) on retrospective cancellation of registration u/s. 12A/12AA, the ld. counsel submitted Hon'ble Allahabad High Court in the case of Agra Development Authority (supra) has clearly held that CIT (Exemption) is not empowered to cancel registration with retrospective effect, i.e., prior to the date of issuance of order/notice. To the same effect, there is another judgment of Hon'ble Rajasthan High Court in the case of Indian Medical Trust v. PCIT, 414 ITR 296. **** 121. One of the key contentions raised by the ld. counsel before us is that the ld. CIT(E) does not have the power to cancel the registration from retrospective date and any such cancellation can only be prospective, i.e., from the date of passing of the order and in support of which certain decisions have also been relied upon. From a bare reading of Section 12AA(3) it is seen that, section provides that where a trust or an institution has been granted registration and if subsequently, Pr. CIT or CIT is satis....
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....a Educational Trust v. Pr. CIT [2019] 108 taxmann.com 385/266 Taxman 105/416 ITR 129 (Madras) which observed as follows: "At the first blush, the Court assumed that the argument of Mr. Anirudh Krishnan is to the effect that the cancellation/withdrawal was with effect from the date of grant of exemption/registration. However, on a perusal of the order dated 18.11.2014 withdrawing the approval granted under Section 10(23C)(vi) of the Act, it is seen that it has been given effect to from the assessment year 2010-2011. Likewise the order cancelling the assessee's registration under Section 12AA of the Act is from the assessment year 20102011. Can it be said that these orders of cancellation are with retrospective effect. The definite answer for this question is an emphatic 'No'. Admittedly, the business premises of the assessee was subjected to search during the assessment year 2010-2011. The Assessing Officer while completing the assessment found large scale diversion of funds and several improper actions on the part of the assessee in direct conflict to the terms of the Deed of Trust and conditions of registration/exemption. Therefore, it was recommended to the c....
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....ation for the first time by enacting sub-Section (3) in Section 12AA only with effect from 01.10.2004 by the Finance (No.2) Act 2004 (23 of 2004) and hence such power could be exercised by the CIT only on and after 01.10.2004, i.e., (assessment year 2004-2005) because the amendment in question was not retrospective but was prospective in nature." 54. The reliance on the CBDT Circular No. 21/2016 dated 27.05.2016 and Sarvodya Pannan 348 ITR 300 (Mad HC); Khar Gymkhana(supra) and Maria Social Service Society (supra)) does not come to the rescue of the assessee. The CBDT's circular only clarifies that it shall not be mandatory to cancel the registration already granted u/s 11 to a charitable institution merely on the ground that the cut-off specified in the proviso to section 2(15) of the Act is exceeded in a particular year without there being any change in the nature of activities of the institution. The case laws relied only prescribes that order for cancellation cannot be de-hors the satisfaction of twin conditions. In the instant case, the registration is cancelled strictly on the grounds of non-genuine activities and activities not in accordance with objectives of t....
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....6 To sum up, we answer the reference holding as under - (1) Exemption notification should be interpreted strictly; the burden of proving applicability would be on the assessee to show that his case comes within the parameters of the exemption clause or exemption notification. (2) When there is ambiguity in exemption notification which is subject to strict interpretation, the benefit of such ambiguity cannot be claimed by the subject/assessee and it must be interpreted in favour of the revenue. 57. In conclusion, we hold that the Society was in cohorts with its ex-president in acting as a conduit for bringing commission/liasoning fees and converting them into cash by taking bogus bills/entries since June 2012. The assessee Society has failed to discharge its onus to strictly demonstrate that its activities were genuine and it was conducting its activities to further its objectives. Since the evidence show that the Society commenced its non-genuine activities that do not align with its objectives, from the year June 2012, the PCIT(C)'s cancellation of Registration order retrospectively w.e.f 27.09.1999, needs some modification as the registration cannot....
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....y, it would lead to anomalous situation. Suppose, if the Income tax Department comes to know about the non genuineness of the trust activities after 1/4/2022 prior to that date, it would be helpless prior to this period as those trust despite engaging in non genuine activities would be enjoying benefit of section 11 to 13 of the act and avoiding taxes u/s 115 TD of The Act up to Ay 2022-23. This is neither the intention of the law nor the law can be interpreted in such manner. 55. Further, circular No. 23/2022 dated 3 November 2022 in paragraph No. 9.5.4 has clearly stated that these powers are available from 1 April 2022 and are not at all restricted to any assessment year. Therefore it is clear that after 1 April 2022, the learned principal Commissioner of income tax is empowered to cancel the registration if specified violations or non-genuineness of the trust is found for any assessment year which can be reopened/reassessed and after 1/4/2004 it is empowered to cancel the registration for that period if the activities of trust are found to be non-genuine. 56. It is also the fact that powers were given to the PCIT for cancellation of registration with effect from 1st Octob....
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.... category of the content by paying them the higher sum is correct. The explanation of the assessee was only with respect to that all these content providers are very renowned, have earned testimony to the quality of journalism produced on a consistent basis. However, there was no reply that when the assessee pays higher sum for a particular topic to the content providers, why the content providers will produce the material or content which is earning them less revenue. Thus, it is true that by paying the higher sum, or creating a rate structure in a manner, the assessee is promoting them to produce more articles on politics etc. a. This fact was not denied by the assessee that when a higher sum is paid, whether the content providers will produce the articles which are earning less. Naturally, the allegation of the learned PCIT was not on the quality of the content of the magazine but the fact that assessee is promoting printing of political articles and trying to control the category of content published by paying higher sum. This is not stated in the object of the trust. Thus, it shows that activity of the assessee is promoting the articles on political agenda by paying the higher....
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....ion was also fed by the assessee to the content providers, we do not find that that is the object of the trust or even if it is object of the trust same is for charitable purpose. 60. The third objection is that assessee is supporting publicization of polarised content. This fact is considered at paragraph No. 5 of the order of the learned principal Commissioner of income tax. The assessee was specifically shown the several articles published by Samarasya Media LLP as well as Janjhwar foundation. The headlines for "harassed for being Muslims", 'Sedition cases in Modi era', "as BJP talks of law against conversion, attacks against Christians rise in Karnataka", "Modi government keeps financial deal with Bharat Biotech secret" and further certain ground reports on issues which are mentioned at page No. 51-52 of the order. On looking at the themes of the articles placed at page No. 53 and 54 of the order it clearly shows that these are polarised contents, and which is not the object of the assessee. Further even otherwise, publishing polarised content which may create any disturbance in the society or are of a political nature, cannot be held to be a charitable activity at a....
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....tity as well as exception in funding to that entity clearly shows that it is promoting the targeted news which the assessee trust wanted to support. Naturally this is not the object of the trust. 63. In view of the above facts, we find that the assessee has carried out the activities which are listed in the order of the learned PCIT which are not in consonance with the object of the assessee. We find that the object of the assessee are promoting excellence in education in the field of journalism but the facts recorded by the learned PCIT shows that it is 'exerting influence for promotion of political articles by paying the content provider more money', it is also 'promoting biased and select articles', 'polarised contents ' and 'grants funds to the profit making entities in the form of professional fees without any evidence of receiving services' from them. 64. Charitable purpose specifically deals with the benefit to the public or a section of public. In this case when the assessee is providing funds to the profitable entities without any stated rendition of services by them in the garb of either professional fees or grant, does not satisfy th....
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....s Primary text Primary text about 550 words 4.000 5,000 about 400 words 8.000 3.500 +Photo /Infographie 6.000 7,000 +Photo /infographie 5.000 5,500 8,000 10,000 + Video News, Analysis Primarytext 600-1,050 words 6.000 9,500 Primary text 450-750 words 4,000 7,000 +Photo /Infographic 8,000 11,500 +Photo/Infographie 6.000 9,000 11,000 14.500 +Video 9,000 12,000 2 [+]|News, Amelyils or Opinion Primary text Primary text 1,100-1,500 words 12,000 15,000 750-1,000 words 10,000 12,000 +Photo/infographie 14,000 17,000 +Photo /Infographie 12,000 14,000 +Video 17,000 20,000 +Video 15,000 17,000 ()|News, Analysis or Opinion Primary text Primary text 1,600 tn 2,000 words 15,000 20,000 1,100-1,400 words 12,000 16,000 17,000 22,000 +Photo /Infographic 14,000 18,000 20,000 25,000 +Video 17,000 21,000 (et| Analysis or Opinion. Primary Video Primary Video include Reports, Analysis, 10,000 15,000 7.500 11,000 15,000 20,000 11,000 15,000 20,000 30,000 8+min 15,000 20,000 15+ 40,000 50,000 90,000 95,000 Primary text 1,550-3,500 werds Primarytext 2.500-5,000 words 25,000 22,000 27,000 37,000 30,000 25,000 ....
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....ented herein by its Chief Executive Officer Mr. Sunil Rajshekhar; AND Delhi Press Patra Prakashan Private Limited, a company registered under the Companies Act, 1956. having its registered office at E-8, Rani Jhansi Road, Jhandewala Estate, Jhandewalan Extensaun Cohmty, Dellsi 110055 and having its present address at -8, Rani Jhansi Road, Ihandewala Estate. Jhandewalan Extension Colony, Delhi- 110055 having CIN No. U74899OL1979PTC010009 (hereinafter referred to as the "Content Provider")'represented by its Directes, Mr Anant Nath; Document 3 means the targets set out in Schedule 5: "Audience Reach Target" . "Commissioned Topics" shall mean the Subjects on which the Content Provider shall Publish Compositions pursuant to this Addendum, more specifically set out in Schedule 1; shall nave the meaning ascribed to it in Schedule 5: "Contracted Value" shall have the meaning exchbed to it In Schedule 5; *Maximum Monthly Payment" *Monthly Composition Publishing Targets" means the target- un out in Schedule.J. shat have the topaning, ascribed to it on Schedule,] read with "Monthly Contracted Value" shall have the meaning ascribed to It in Clause....
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....E Z PAYMENT TERMS RATE CARD FOR PAYMENT FOR COMPOSITIONS PUBLISHED BY CONTENT PROVIDER Topics . Politics Governance, Policy, Corruption 1,00,000 Econonly, Business, Free Press 1,00,000 Low & Society 1,00,000 Agriculture. Health, Water Rural India 50,000 Defence and Strategic Affairs 50.000 Digital Governance, Science and Technology and Privacy 50,000 Education, Livelihood & Environment 50,000 : Books, Indian History, Art & Culture 50,000 Regional, Rural, Society 50,000 Payment tor published compositions will be based on the following two criteria: · Word length - how comprehensive, and . Time spent on in-depth reporting. Accordingly, payment for stories are as below: . Rs.100,000 o for storles with word count of 2,000 and above, or & for investigative stories with word count between 1,500 - 2,000 requiring considerable effort, time for cultivating sources, reporting, editing and fact-checking · Rs.50,000 o for storles with word count between 1,000 -2,000 words IPSMF reserves the right to review the above rate card and make appropriate changes when necessary, during the Term, subject to acceptance of these chan....
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....2026/1/2Wwpart.indian-embassy begins probe into Arsedom lee issue lolowing the-lodes.expose The Lede expose on "freedom feet demanded from domestic workers in Kuwait to also go to Kerala High Court Participant Delivered Read Played 91996101055595 whatsapp net 23-01-2020 23-01-2020 Muhammed Suhail M. 09:22:21(UTC+5:30) 09:42:25(UTC +5:30) 09:42:25(UTC +5:30) Status: Road Pladorm: Mobda 23-01-2020 09.22:20(UTC+5:30) Source Into Sunis Phone/mobile/Contaners/Shared/AppGroup roup net whatsapp. WhatsApp shared/ChatStorage sqlite Dx2888F44 (Table ZWAMESSAGE, ZWAMESSAGEDATAITEM, ZWANEDIAITEM, Sune 204902400 bytes) Phoneimobile/Containers/SharediAppGroupigroup net whatsapp WhatsApp shared/Library/Preferences/group net whatsapp WhatsApp shared plist : Ox 1003 (Size: 18527 bytes) Susis Phongling ble/Contariers/Shared/AppGroup/group net whatsapp.WhatsApp.shared/ContactsV/2 sqlite QLA4617 (Table ZWAADDRESSBOOKCONTACT, Size: 1253376 bytes) Phone/mobile/Containers/Shared/AppGroup/group net whatsapp WhatsApp shared/Message/Media/919961010555@s whatsapp net/u/b/cha60 518-0610-4854-85c2-443de14dodle thumb: (Sie: 2011 bytes) Document 7 From: [email protected]....
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.... case of fake journalists and fake publications as a result of this and Impleaded: Secretary, Information and Public Relations Department of the Goverment of Tamil Nadu, Press Council of India, Madras Union of Journalists (MUJ), The Madras Reporters Guild and Chennal Press Club. .The Bench posted the case for hearing on 21 January 2020 and asked the impleaded parties to answer the following questions: oHow many newspapers or magazines including weekly as well as fortnightly are registered with the Government of Tamil Nadu for the past 10 years? [year wise details in each category such as magazine or newspaper have to be givenj. oHow many persons are issued with press identity cards totally by the Government? aAre cases registered against people who are daiming to be press reporters for indulging in criminal activities? If it is so, how many cases have been filed and the present stage of those cases? oWhether people claiming as Press reporters are indulging in blackmailing and conducting Katta Panchayat? ols there any Government scheme for the benefit of press people in case of any accidents or untimely death? oWho are all the members of the Accreditation commit....
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.... bytes) Sunils Phone/mobile/Containers/Shared/AppGroup.group net whatsapp WhatsApp shared.Message" Media/919900097142G's whatsapp net/t/4/4643bd7-6909-4e04-8c10-124651b6d3e4 pdf (3ze 319334 bytes) From: 919900035412Gs whatsapp.net Sunil Rajshekhar (owner) To: [email protected] Vignesh Vellore Sandhya Ravishankar of The Lede, has impleaded in the above case. This story may interest TNM readers Participant Delivered Resd Played 919900097142Gs.whatsapp.net Vignesh Velore 21-01-2020 14:36:21(UTC+5:30) 21-01-2020 14:36:21(UTC +5:30 Status: Read Platform Mobile 21-01-2020 14:36:19(UTC+5:30) Source info Sunts Phone mobile Cortaners/ Shared AppGroup group net whatsapp WhatsApp shared CharStorage sqlite 0x28802F2 (Table EWAMESSAGE, Ser 204102400 bytes) Phoneiroble Containers Shared AppGroupgroup ret whatsapp Wh tsApp sharedlibrary: Preferences group net whatsapp WhursApp sha med plist : Dx 1003 (Score 18527 bytes) Sunis Phone mobile Certanens Shar up/gong net whatsapp WhatsApp shared ContachV/2 sqlite DvGA175 (Table ZNAADDRESSBOOKCONTACT, Saw 1253376 bytes) Document 10 From: 919900035412@s whatsapp nef Sunil Rajshekhar (owner) To: 9198107875....
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....sees-smaller-changes/ "A now Pow Research Center analysis finds that the middle class in India is estimated to have shrunk by 32 milion in 2020 as a consequence of the downturn, compared with the number it may have reached absent the pandemic. This accounts for 60% of the global retreat in the number of people in the middle income bier (defined here as people with incomes of $10.01- $20 a day) " Attachments: Size: 10120 Fin nare The course of the pandenue in links and China will have a subalantal elfed en changes in the dietristen of europe al Pel The course of the pandemic in India and China wil have a substantial effect on changes in the dotnotion of Participant Delivered Read Played 919811112274@s whatsapp nel Barkha 06-04-2021 06-04-2021 Dutt 12.15:35(UTC+5,30) 1237.OXUTG +5:30) Padome Web 06-01-2021 12 15 3/(UTC+5.30) ZWAMESSAGE. ZWAMESSAGEDATAITEM, ZWAMEDIA/TEM, Se 204102400 Bytes) piet CH1D03 (Site 18527 bytes) we/Conta pigroup net wtharsape whatsapp shared/Contacts/2 agite QuADABA (Table ZWAADDRESSBOOKCONTACT, Soe 1253176 bytes) From: [email protected] Sunil Rajshekhar (owner) To: 919011112274625 whatsapp net Darkha Duft This....
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....e Nows Minute Spunklane 2 16 2.10 0.04 The Ken 1.40 1 31 The Swar ajya_Kova 2.50 0 46 Dool News 2.10 2.00 The Print - English 6 85 1.00 Satyagrah - SRCNS 1 20 Suno India - FVMPL 1 10 Ippodhu 1 00 0.53 The Caravan- Dethe Press 5.00 4 11 1 44 Max Maharashtra U 23 Sikkim Chronicle - Yanka info 1.00 0 84 East Mojo - Atw 2.20 2 04 0.13 Auanille 2.10 2.05 Live History India 3.00 0 45 Whatart aberanys Chambyl TheLede - FIVEWS LLP 25 0 86 The Best-un 0 95 0 85 Feminism in india 1 10 1.00 0 10 Kathmit Observe 0.90 0.73 017 Main Media The Probe 0.75 0.44 Mojo Story - Barkha Dutt 2.20 1 20 Article14 0.90 .... Thecitizen 0.50 0 3/ 013 HW News 1 00 0 57 0 42 Democratic Charkha 0.60 0 50 0.60 TrueCopy Think 0 50 0 24 0 25 Total Content Commissioning 56.77 46.07 8.23 Document 15 2. Pravda Media Foundation -Alt News www.altnews.in Grant Term-3 Completed on March 31, 2022 - Total Grant over 3 Terms - Rs. 2.25 Cr The Board was Informed that while Alt News had informally placed a request for 4% Term grant renewal to support its Bangla and Kannada editions, it had not submitted any details to the F....
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