2025 (2) TMI 1630

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.... Dhariwal, CIT-DR, Ld. DR ORDER PER GAGAN GOYAL, A.M: This appeal by the assessee is directed against the order of CIT(E), Jaipur dated 30.09.2024 passed u/s. 12AB(1)(ii)(B) the Income Tax Act, 1961 (in short 'the Act').The assessee has raised the following grounds of appeal: 1. The Ld. CIT(E) has erred on facts and in law in rejecting the application filed by the assessee u/s. 1....

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....by the ex-ruler of Kuchaman, Raja Hari Singh Ji in which his wife Rani Prem Kumari Ji, his daughter Rajlaxmi Shah and Shri Babu Bhai Kastur Chand Shah were the trustees. Vide his letter dated: 15.02.1979, ex-rule donated his immovable property consisting of the Fort of the Kuchaman to the trust. The applicant filed an application in form no. 10AB seeking registration u/s. 12AB of the Act vide date....

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....t to analyse the audited financials of the assessee first then legal issues may be examined. We have gone through the audited balance-sheet, income & expenditure account and receipt and payment account of the assessee and observed as under: A) Corpus of the assessee is in negative, rather if the security deposit of Rs. 5.24 Cr. from lessee M/s. Marwar Fort & Palace Pvt. Ltd. (Which is act....

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.... reflects that the assessee does not have any contribution from the public or from any of the charitable activities as such. Rather receiving Lease Rent and Tower Rent from M/s. Marwar Fort & Palace Pvt., M/s. Bharti Hexacom Limited and M/s. Indus Towers Limited respectively there is no other receipt which can be categorised and establishes that the assessee trust is a public charitable and religi....