TMI Blog2013 (12) TMI 1198X X X X Extracts X X X X X X X X Extracts X X X X ..... e trust activities, as all its activities are for the members enrolled - The activities cannot be in any manner classified as being charitable in nature - Apart from administrative heads of expenditure, no other expenses were shown to have been incurred on any charitable activity – Decided against assessee. - I.T.A. No. 5925/Del/2012 - - - Dated:- 8-2-2013 - Shri R. P. Tolani And Shri Shamim Yahya, JJ. For the Petitioner : Sh. R. Venkataraman, CA For the Respondent : Sh. Tarun Seem, Sr. D.R. ORDER Per Shamim Yahya: AM This appeal by the Assessee is directed against the order of the Ld. Director of Income Tax (Exemptions), Delhi dated 20.9.2012. 2. The grounds raised read as under:- 1. That the Ld. Director ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... contribution from companies was at ₹ 1,55,000/- Assessee was asked to provide a note on the activity carried out since its inception of the trust and details of subscription and donation received. On going through the reply, Ld. Commissioner of Income Tax found that the assessee was charging money for registration and subscription from the enrolled students totaling to ₹ 14,000/- per student who gets placement through it and similarly the companies coming to the campus for providing employment to the enrolled students to DSE have to pay 3 tier subscription on the basis of participation i.e. Zero day, day one and two ₹ 20,000/-, ₹ 15,000/- and ₹ 10,000/- respectively. Furthermore, Ld. Commissioner of Income Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for providing placement to the students in their organizations. Thus public at large is neither eligible to become a member nor is provided any benefit of the trust activities, as all its activities are for the members enrolled. These activities cannot be in any manner classified as being charitable in nature. Further, apart from administrative heads of expenditure, no other expenses were shown to have been incurred on any charitable activity. In the absence of documentary evidences, it cannot be held that the applicant's activities are charitable in nature. In view of above facts, it is held that the applicant does not fulfil the conditions laid down for grant of registration u/s. 12A of the I.T. Act. Accordingly, the applic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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