2025 (4) TMI 1914

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....akesh Ranjan, CIT-DR ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned order dated 28/12/2024 passed by the learned Commissioner of Income Tax (Exemptions), Mumbai ["learned CIT(E)"], rejecting the application filed by the assessee seeking registration under section 80G of the Income Tax Act, 1961 ("the Act"). 2. In this appeal, the as....

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....th sides and perused the material available on record. The brief facts of the case are that the assessee is a Trust and filed an application in Form 10AB, requesting approval under clause (iii) of first proviso to section 80G(5) of the Act. Upon verification of the application in Form 10AB filed by the assessee, it was found that the application was incomplete, and all the documents required to ac....

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....uality education to Indian students in India. The learned CIT(E), vide impugned order, after noting the objects of the Trust, concluded that the same conveys the intention of the Trust to utilise funds outside India, thereby leaving the possibility for future endeavours, which may involve expenditure outside the country. The learned CIT(E) further held that the assessee Trust ought to have amended....

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....there any intention to do so in future. The learned AR further submitted that the Trust has initiated the process of modifying the provisions of its Trust Deed, which shall now specifically provide that the area of operations of the Trust will be restricted to territories of India only and not outside India. In this regard, the learned AR placed on record the draft copy of the scheme under section....