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2023 (9) TMI 684 - ITAT DELHIApproval u/s 80G Denied - Real purpose to construct a building not known - no emphasis whatsoever on the objects on the basis of 12AA Registrations was accorded - Revenue submitted that the applicant generated huge resources in the name of building construction even the said building construction was to be financed by/from MPLADS and constructed by Government of Haryana, the appellant had not evidenced whether the money generated was handed over to the Government of Haryana which was to construct the building and handed over to the society - HELD THAT:- PCIT found that the expenditure for the building was to be financed from MPLAD Scheme and construction was to be undertaken by the Government of Haryana till the building was handed over to the Society. Though the assessee has specifically urged a ground against the observation and the conclusion of the CIT(A) that the ‘construction has to be undertaken by the Government of Haryana till the building was handed over to the society’ but the assessee has not produced any evidence/document in support of the said contention of the assessee to controvert the findings of the CIT(A). The action of the CIT(E) in relying on the agreement entered into between Government of Haryana and the appellant society and concluding that the construction was to be undertaken by the Government of Haryana to till the building was handed over to the society in accordance with law and we find no error in the said observation. Thus, we find no error or infirmity in the order of the CIT(E) in rejecting the approval u/s 80G of the Act, accordingly, Grounds of Appeal of the assessee are dismissed.
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