9911796707
TMI Blog2025 (5) TMI 953X X X X Extracts X X X X X X X X Extracts X X X X ..... 2023. With a view to verify the genuineness of activities of the assessee and compliance to requirements of any other law for the time being in force by the trust/institution as are material for the purpose of achieving its objects, a notice was issued by Ld, CIT, Exemption, Pune through ITBA portal on 17.01.2024 requesting the assessee to upload certain information/clarification. In reply to the said notice, the desired information was furnished by the assessee. On verification of the information furnished by the assessee, Ld. CIT, Exemption, Pune found certain discrepancies, therefore, issued another notice on 26.04.2024 and asked the assessee to furnish following details:- "(i) The object No.- 4 (o,u,v) of the trust deed/MoA are found ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ld. AR further submitted before the Bench that all the requisite details were furnished before Ld. CIT, Exemption, Pune but the application for permanent registration filed in Form 10AB under clause (iii) of section 12A(1)(ac) of the IT Act was rejected by Ld. CIT, Exemption, Pune and the provisional registration granted on 01.10.2021 u/s 12AB r.w.s. 12A(1)(ac)(vi) of the IT Act was also cancelled. Ld. AR also furnished a paper book wherein various documents such as trust deed, registration certificate issued by Charity Commissioner, Pune, audited financial statements for financial year 2021-22 to financial year 2023-24 and acknowledgement of income tax return for above years was produced before the Bench. Apart from above details copy of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onies, funerals, and baptisms conducted according to gospel principles, the trust provides essential spiritual services related to the beliefs and practices of Christians. Further, the emphasis on ordained pastors ensures that the community receives guidance and leadership grounded in the Christian faith. Overall, these objectives are aimed at benefitting and strengthening of the Christian community by promoting its spiritual growth and adherence to the teachings of Christ, rather than serving the people at large. 5.1 Regarding note on activities, the assessee was requested to furnish details like dates and places of each activities carried out by you, details of beneficiaries, how they were identified. In reply, the assessee has only st ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een furnished by the assessee to prove its contention. Even in that case, the assessee was required to estimate the value of food grain collected and disclose it in the financial statements. The assessee has attached few bills/ invoices. However, the activities in connection with which said expenses are incurred, has not been explained by the assessee. 6. In view of the above, the undersigned is not satisfied about the charitable nature and the genuineness of activities of the assessee and compliance to requirements of any other law for the time being in force by the trust / institution as are material for the purpose of achieving its objects. Therefore, the application filed by the assessee is hereby rejected and the provisional registr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ll details in respect of above donations were not furnished by the assessee trust and only a few receipts as mentioned above which does not contain all the requisite details was furnished and therefore, Ld. CIT, Exemption, Pune was of the view that the source and genuineness of these transactions have remained unproved. 9. Ld. CIT, Exemption, Pune on the issue of ration distribution observed that the assessee was required to estimate the value of food grain collected and distributed and also required to disclose it in its financial statements but this was also not done by the assessee. In this regard, we find that in the ground no.6 of appeal the assessee trust himself admitted that even if the activity is undertaken by the assessee trust ..... X X X X Extracts X X X X X X X X Extracts X X X X
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