TaxTMI 
TaxTMI 
2025 (7) TMI 1991
X X X X Extracts X X X X
X X X X Extracts X X X X
....f the Act, holding that most of the objects of the assessee are for the benefit of Rajput Kshatriya Samaj, therefore, the Trust is for any particular caste and community and hence the assessee is not eligible for registration u/s 12A(1)(ac)(iii) of the Act. 2. The Ground of appeal raised by the assessee are as follows: "(1) The Learned CIT (Exemption) erred in law and is not just in facts in rejecting the application for regular registration under section 12AB of the Act and also cancelling provisional registration of the appellant trust (2) The Learned CIT( Exemption) erred in law and is not just as facts of the case in holding that the activities of the appellant trust are not conducted for the benefit of general publ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... of RAJPUT KSHTRIYA SAMAJ/community and are not for the benefit of public at large. Accordingly, a show cause notice was issued to the assessee on 20.09.2024. 4. In response to the above show-cause notice dated 20.09.2024, the assessee has submitted its reply on 24.09.2024 before learned CIT(E). In its reply, the assessee stated that the objects of the trust are for general- public utility and the mention of word "community" in the deed is for general public not for particulars Rajput Kshatriya Samaj. The assessee submitted that as per para 5 to para 11 of the constitution of the trust, in which there is mentioned about the socio-cultural activities and other Charitable activities for the general public and not for any particular religio....
X X X X Extracts X X X X
X X X X Extracts X X X X
....B(4) of Income Tax Act, 1961.Therefore, assessee's application filed in Form No.10AB, u/s 12A(1)(ac)(iii) of the Act was rejected and provisional registration was also cancelled by the learned CIT (E). 6. Aggrieved by the order of Ld. CIT(E), the assessee is in appeal before us. 7. Ld. Counsel for the assessee, at the outset argued that during the proceedings before Ld. CIT(E), the assessee has not submitted entire documents and evidences, to prove its objects. Moreover, the assessee trust was registered with charity commissioner of Kutch on 29-12-2018. The assessee trust has not incurred any expenditure on any of the objects of the trust. The Ld. Counsel also submitted that no doubt some of the objects of the assessee trust are relig....
X X X X Extracts X X X X
X X X X Extracts X X X X
....gistration u/s 12A(1)(ac)(iii) of the Act, as the assessee is having charitable activities only for the benefit of Rajput Kshatriya Samaj Community. Therefore, the trust falls under the specified violation under cause (d) below explanation to section 12AB(4) of the Act. Hence assessee's appeal may be dismissed at this stage. 9. We have heard both the parties and perused the material on record. We note that no doubt all 11 objects of the trust are charitable in nature and they are confined for the benefit of Rajput Kshatriya Samaj Community. The Trust under consideration is recently registered with Charity Commissioner, Kutch on 29-12-2018. The Ld. Counsel for the assessee submitted that the Trust has not started any activities. Therefore....