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TMI Blog2020 (5) TMI 591X X X X Extracts X X X X X X X X Extracts X X X X ..... in law, the learned Commissioner of I.T (E) Pune is not justified in rejecting the application for registration when the trust fulfills the conditions of section 2(15), 11, 12AA. The registration may please be accorded. 2. On the facts and circumstances of the case and in law, the learned Commissioner of I.T (E) Pune is not justified in rejecting the application for registration under section 12AA of the IT Act when the Trust exists solely for education and advancement of general public utility and not for profit. The trust may please be registered under section 12AA. 3. On the facts and circumstances of the case and in law, the learned Commissioner of I.T (E) Pune is not justified in rejecting the application on the presumption that t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... emy of Development of Administration, Pune (Yashada) which is father trust for the state government employees training institute has been issued 12A of the Act. The Ld. AR of the assessee submitted that the Ld. CIT(Exemption) rejected the said application of the assessee as there is no fresh facts, was brought to the notice of Ld. CIT(Exemption) other than the reasons mentioned for rejection order passed by the Office on 27.12.2012 wherein it was held that the assessee is not doing any general charitable activities of public utility and was into training Departmental Officers and Staff of the State Revenue Department. 3. The Ld. DR for the Revenue has placed strong reliance on the orders of the lower Authorities. 4. We have heard the riva ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the trust, the applicant also expects to enhance its financial capacity through such activity. Therefore it cannot at all be termed as an activity for the benefit of public at large. 5.3 As regards the contention of the applicant that earlier rejection order dated 09.01.2013 was on account of non compliance such contention is totally ill founded. The reason for rejection- as prescribed in the earlier paragraph of this order itself shows that the relevant authority has also discussed the merits of the case in detail. Further the applicant has not submitted any material/facts now to require the undersigned to deviate from the observations made in the earlier rejection order dated 09.01.2013. 5.4 Lastly as regards the contention of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , we may rely upon the decision of CIT Vs. Andhra Pradesh Police Welfare Society 148 ITR 287 (Andhra Pradesh) and Water and land Management Training Research Institute DIT 40 ITR (Trib.) and DIT Vs. National Safely Counsel 305 ITR 257. In all these decisions, it was held that the object of general public utility is wider and larger object which encompasses the object like imparting the training to the Govt employees working in various Department and Revenue. The Govt. Employees working with state govt. belongs to various state of the society and they are not restricted to one religion, caste or creed. If there is an improvement in their workmanship and the managerial skill then it will indirectly benefit the public and also to the Governmen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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