TMI Blog2014 (9) TMI 319X X X X Extracts X X X X X X X X Extracts X X X X ..... The trust is one and the same namely Dr. R.K. Dhote Public Charitable Trust - the Tribunal has not committed any error in holding that the material was not enough to refuse the request of renewal of the certificate u/s 80G - this was a case of mere renewal and no wider controversy or larger question was involved - the reasons assigned by the Tribunal are in conformity with the factual position – ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r raises substantial question of law. The Tribunal failed to note that the Director found that two trusts were amalgamated into the single trust by order passed in the year 2001 by the Assistant Charity Commissioner. Later on, in the garb of seeking renewal of the exemption under section 80G of the Income Tax Act, 1961 what the assessee attempted to do was to apply the original certificate to a al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... g on behalf of the respondentassessee urged that the Tribunal's order notes and considers the admitted factual position. There the Tribunal has rightly relied on the fact that there were two trusts Mrs. Tarabai Ramhari Dhote Public Charitable Trust and Dr. R. K. Dhote Public Charitable Trust. These two trusts amalgamated and order of Assistant Charity Commissioner dated 4th October, 2001 state ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h circumstances, non-renewal of the certificate was the issue and which has been answered in favour of the assessee and against the revenue. That does not give rise to any substantial question of law. 4. We have heard both sides and with their assistance we have perused the memo of appeal and all annexures thereto. We do not find any basis for the argument now canvassed to support the findings ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cts justified the direction to renew the certificate and which is the conclusion of the Tribunal. We are of the opinion that the reasons assigned by the Tribunal from para 4.1 of the impugned order are in conformity with the factual position noted above and which was never disputed. In such circumstances, the reasonable request to renew the certificate has been rightly granted. There is no substan ..... X X X X Extracts X X X X X X X X Extracts X X X X
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