2026 (8) TMI 1357

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.... circumstances of the case the Ld. CIT(Exemption) erred and was not justified in holding that the rent paid by the society to the Member of the society for taking their land on rent for running of the Educational Institutions run by the Society is for the purpose of providing profit to the office bears and not for charitable purposes. 2. That the Ld. CIT (E) has erred in law and on facts in holding that the activities of the appellant are not genuine merely on the basis of doubts raised regarding lease documentation and rent expenditure. The appellant society is admittedly engaged in the field of education which squarely falls within the definition of "charitable purpose" under section 2(15) of the Act. Accordingly, the impugned re....

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....ng block reflected in its, fixed assets, the applicant has claimed substantial and sharply increasing rent expenditure over the years without furnishing credible and legally enforceable lease documentation. The explanation furnished by the applicant is not supported by reliable documentary evidence and fails to satisfactory, explain the inconsistency between the ownership of building assets and payment of rent. 4.3 Here, it would also be pertinent to note that the Hon'ble Supreme Court in the case of CIT(Exemption) vs. Jagannath Gupta Family Trust dated 01-02-2019[2029] 411 ITR 235 (SC), noted that the Hon'ble High Court had allowed the writ petition mainly on one ground i.e. one bogus donation would not establish that the activiti....