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2016 (10) TMI 1150 - AT - Income TaxNon granting of exemption u/s 11 - finding of the A.O. that “the assessee’s main activity for the year under consideration is to run coaching classes by collecting hefty fees for every kind of services” - Held that:- We find that a categorical finding is given by the A.O. on page 7 of the assessment order that the assessee’s main activity for the year under consideration is to run coaching classes by collecting hefty fees for every kind of services. Even before CIT (A), the assessee has filed nothing to controvert these findings of the A.O. The submissions of the assessee before CIT (A) are available on pages 233 to 261 of the paper book as per which, the assessee has filed copy of Registration certificate u/s 12AA, Copy of Trust Deed and Financial Statements for F Y 2010 – 11. Before us also, no evidence is filed to controvert this finding of the A.O. The Activity report on pages 36 to 38 of the paper book is a report about which, even this is not known as to who prepared this report and on what date or in which year. Such a vague report has no evidentiary value. Hence, we proceed on this basis that the assessee has nothing to say about this finding of the A.O. that “the assessee’s main activity for the year under consideration is to run coaching classes by collecting hefty fees for every kind of services” - Decided against assessee.
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