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2020 (12) TMI 563 - AT - Income TaxApplication of registration u/s.12AA rejected - charitable activity u/s 2(15) - without providing proper opportunity of hearing to the assessee and on the ground that the activities are commercial in nature - HELD THAT:- Assessee filed application in Form No.10A, for registration u/s.12AA - CIT(E) has issued notices to the assessee to produce its original memorandum of association/trust deed for verification, in response to which, the assessee has filed reply on 3.9.2019. Later on also the case was posted for hearing on 11.9.2019 and ld A.R. of the assessee attended the hearing and the matter was discussed. From the above, it cannot be inferred that the assessee was not provided proper opportunity of hearing. Section 2(15) of the Income-tax Act defines charitable purpose for the purpose of the Act and includes relief of the poor education, medical relief and the advancement of any other object of general public utility. But in the present case, the assessee trust is collecting fees from different organisations towards training programme and also received rent for letting out the part premises. Nowhere, the assessee has done the work, which can be treated as charitable purposes. Hence, we dismiss the appeal of the assessee.
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