2024 (4) TMI 1429

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.... 2. The Assessee has taken the following grounds of appeal:- "1. That the Ld. CIT(E) has erred in law and fact by rejecting the application for the approval under section 80G(5) of the Act vide his order dated 16/3/2023 and therefore the ld. CIT(E) is to be directed to grant approval under section 80G12AB of the Act. 2. That your appellant craves a leave to add, alter or amend any grounds at the time of hearing." 3. The brief facts of the case are that the assessee / applicant filed application for approval of trust under Section 80G(5) of the Act in Form 10AB on 02.09.2022. On perusal of application filed by the applicant, assessee, the CIT(E) observed that in Form No. 10AB, the assessee has mentioned nature of acti....

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....ily dismissed the application for grant of deduction under Section 80G of the Act. The counsel for the assessee submitted that the Ld. CIT(E) has very selectively cited a few of the objects of the assessee trust to come to the conclusion that the assessee is carrying out religious activity and further did not even analyze whether the assessee trust had incurred expenditure of a religious nature exceeding 5% of it's total income. Accordingly, the Counsel for the assessee submitted that the order passed by Ld. CIT(E) was passed a summary manner, without appreciating the facts of the assessee / applicant's case. 5. In response, Ld. D.R. placed reliance on the observations made by the Ld. CIT(E) in it's order dated 16.03.2023. 6. We have ....

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....ealth centers and yogashram. (iv) To arrange for religious and/or formal educational seminar or to help in its arrangement. (v) To donate to the Institution working for animals and/or birds and to donate for religious solemnization and to help to donate for food and Journey of saint. (vi) To arrange for "Aahar - Vihar of Sadhu - Saint (vii) To arrange for lecture meetings of Sadhu Saint and for that to arrange for Upashray and maintain the same. (viii) To arrange and manage Dharmik Educational School le Gyanshala and to educate the students for Dharmik Education and to inspire them with the help of the Donors. (ix) Education Related: ⮚ To provide books, equipments and to ....