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TMI Blog2024 (7) TMI 220X X X X Extracts X X X X X X X X Extracts X X X X ..... 1. 2. Brief facts of the case are that appellant filed applications dated 28.03.2023 in Form No. 10AB seeking registration under Section 12A(1)(ac)(iii) and 80G (5) clause (iii) of first proviso of the Income Tax Act, 1961. The applicant was issued a questionnaire on 25.05.2023 with a request to furnish certain details and documents in support of its claim for registration on or before 09.06.2023. The applicant uploaded certain details and documents on 18.07.2023. Reply was also submitted by appellant vide letter dated 5.9.2023 and requested to submit the documents and clarifications by 12.09.2023. No reply was furnished by the appellant. Another opportunity was afforded. In reply to the notice dated 15.09.2023 appellant uploaded bank ledg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ve of appellant/assessee stated that Learned CIT(Exemption) erred in appreciating that letter dated 17.07.2023 (page 68 to 70 of the Paper Book) at page No. 69 mentions :- "K.J Somiya (Delhi) Trust was founded by Late Padmabhushan Shri Karamshibhai Jethabhai Somiya with a view to establish and nucleate renowned Educational Institutions i.e replica of Somaiya Vidyavihar, a premier education institute at Mumbai, at the prime location of Delhi, Gurgaon. As a first move, the Trust has acquired/purchased the land in the prime location of Delhi, so as to enable to create an educational hub for the society at large. In furtherance of aims and visions of the Trust, the Trustees are promoting the education by way of giving substantial financial as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... her the activities which the Trust proposed to carry on are genuine in the sense that they are in line with the objects of the Trust." 9. Both the appeals are inter connected having same facts so they are taken up together. ITA No. 3353/Del/2023 is against the order dated 26.09.2023 seeking registration under section 80G(5) of the Income Tax Act, 1961 and ITA No. 3354/Del/2023 is against the order dated 26.09.2023 seeking registration under section 12A(1)(ac(ii) of the Income Tax Act, 1961. 10. Learned authorised representative for department of revenue submitted that in Form 10B, Independent Auditors Report, Balance sheet and income and expenditure accounts as on 31.03.2020. Page 40 of Paper Book shows total worth of property & assets Rs ..... X X X X Extracts X X X X X X X X Extracts X X X X
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