TaxTMI 
TaxTMI 
2026 (4) TMI 1249
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....ration u/s. 12A. (2) The learned CIT(E) was not justified in invoking Explanation to Section 12AB(4) by holding as though, the appellant was covered by "Specified violation". (3) The learned CIT(E) deprived the appellant from the opportunity to counter with the physical inquiry, defined the natural justice. (4) The above grounds are prejudiced to one another. (5) The appellant craves leave to add, alter or vary any of the grounds of appeal." 3. The applicant trust was registered u/s. 12A of the Act. The applicant trust was registered with Charity Commissioner under Bombay Public Trust Act, 1950. The applicant trust was registered under Gujarat State Waqf Board on 22-07-202017. The applicant trust filed....
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....cordance with the prescription of the trust be it religious or charitable. The ld. A.R. submitted that the stipulation of the trust deed categorically mentions the objects of the trust as well as the activities which is in the public. The ld. A.R. submitted the audited accounts. The ld. A.R. further submitted that there is no denial that the charging is not done. The ld. A.R. further submitted as follows: * Gulam Arif Will Wagf is over 100 years old Trust, and came to be settled in the year 19-4-1902 in Rangoon through Will of Gulam Arif. It held properties in Surat which continues to be held by the appellant * The appellant has given sufficient evidence to demonstrate that Trust was settled 100 years back i.e. before the ....
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....mmunity. The word "Sunni" is derived from the word "Sunnah" which as per wikipedia is that in the pre-Islamic period, sunnah was used to mean "manner of acting", whether good or bad. Based on those who followed practices of Islamic prophet Muhammad, were known as "Sunnah" or "Sunni". • "Bohara" (or "Vohara") mean Bohara is a name of Indian (Sanskrit) origin that means "Brave and clever". The name is a corruption of a Gujarati word, vahaurau, meaning "to trade". So, Vohara is essentially a trading community like Patidar or Patel who are an agriculture community. * Also, the activities undertaken for a specific section or class also qualifies to be charitable and is not said to be carried out for a particular community o....
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....one. This common quality he said was "definable by reference to what each has in common with the others and that is something into which their status as individuals does not enter". Andrew, L.C.J. accepted this statement of law without hesitation in Trustees of the Londonderry Presbyterian Church House v. Commissioners of Inland Revenue(2). What has to be seen in the present case is whether the members of the Rana caste who are not natives of Ahmedabad but who come to reside there and are accepted as members of that caste according to its usage and customs can be said to have a relationship which is an impersonal one dependent on their condition as members of the Rana community. We are unable to comprehend how such members of the Rana caste....
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....p to a single propositus or to several propositi, they are neither the community nor a section of the community for charitable purposes". The personal element of personal relationship which takes a group out of session of the community for charitable purposes is of the nature which is to be found in cases of the aforesaid type. We cannot possibly discover a similar element of personal nature in the members of the Rana community who settle in Ahmedabad and have been accepted by the Rana community of that place as members of that community. As regards the acceptance of such persons as members of the community or caste, according to custom and usage, it is well known that whenever a question arises whether a person belongs to a partic....