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2023 (7) TMI 616 - HC - Income TaxExemption u/s 11 - application for registration u/s 12AA rejected - Assessee is into promote the game of Tennis and all other sporting activities - there is no element of charity in the activities of the assessee as reflected from said order of CIT in the assessment years considered - ITAT setting aside the order gives rise to substantial questions of law, on which the appeal be admitted - HELD THAT:- The accounts for assessment years considered reveal that there was construction undertaken for having tennis court. Construction of tennis court appears to be furtherance of the objectives. Another reason given by the CIT, for rejecting the application for registration, is future contingency as would appear from second paragraph of the order, reproduced above. Where section 12AA, by the sub-sections therein provides for cancellation of the registration, rejection of the application for registration based on a projection of what might happen in future, cannot be sustained. In the circumstances aforesaid we do not find that a substantial question of law arises from impugned order made by the ITAT. Decided against revenue.
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