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Income Tax Appellate Tribunal, DELHI BENCH “A”: NEW DELHI
Before: SHRI BHAVNESH SAINI & SHRI PRASHANT MAHARISHI
O R D E R PER PRASHANT MAHARISHI, A. M. 1. This appeal is filed by a Charitable Trust appellant against the order of the ld CIT(Exemption), Delhi passed u/s 12AA of the Act rejecting the application for registration u/s 12A of the Act of the assessee trust. 2. The assessee raised the following grounds of appeal:- “1. That the learned Commissioner of Income Tax (Exemptions) has grossly erred both in law and on facts in rejecting the application for registration of the assessee trust u/s 12AA(l)(b) read with section 12A of the Act
2. That the impugned order has been made in an arbitrary and whimsical manner and that too without giving any opportunity of being heard much less a fair opportunity and as such the order passed is against the principles of natural justice.
3. That various adverse findings recorded in the impugned order are not only contradictory, vague but also factually incorrect, legally misconceived and untenable.
4. That the learned Commissioner of Income Tax has failed to appreciate that, while examining the application under section 12AA of the Act, the scope was to merely examine the section 12A of the objects of the trust and, whether income received by the assessee trust is liable to be considered under section 11 and 12 of the Act Page | 1