2025 (2) TMI 1630

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....R 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. 12A(1)(ac)(iii) in Form No. 10AB s....

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.... 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 dated: 27.03.2024. After considering ....

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....ls 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 actually refundable) would not have ....

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....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 religious trust. E) Same I & E....