Ananda Social and Educational Trust v. CIT

426 ITR 340Supreme Court of India2020#918 most cited

What is Ananda Social and Educational Trust v. CIT authority for?

For registration under Section 12AA, the Commissioner (Exemptions) must examine the objects of the trust and the genuineness of its proposed activities, even if the trust has not yet commenced actual charitable activities or incurred expenditure.

116

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2017 to 2026.

Also referred to as

Ananda Social and Educational Trust v. CIT · section 12AA registration · proposed activities · genuineness of activities · charitable trust registration · Commissioner (Exemptions) · objects of trust · Section 12A · Section 12AB · Section 80G · eligibility for registration

Also reported as

114 Taxmann.com 693272 Taxmann 7

Sections most often in play

Section 12ABSection 12AASection 80GSection 11Section 12ASection 2(15)Section 12Section 12A(1)(ac)(iii)
Read the full judgment

Issues it is cited on

section 12ab(1)section 12ab(1)(b)section 12ab(1)(b)(i)section 12aasection 12ab(1)(b)(ii)section 2(15)section 12absection 12a(1)(ac)(vi)corpus donationregistration under section 12asection 12a(1)(ac)section 13(1)

Judgments citing Ananda Social and Educational Trust v. CIT

Ekal Gramothan Utpad Foundation, Delhi vs. Commissioner of Income-Tax (Exemption), New Delhi

In the result, both the Appeals filed by the assessee are allowed for statistical purposes

ITA 322/DEL/2024[2022-23]Status: DisposedITAT Delhi18 Nov 2024AY 2022-23

Bench: Shri Pradip Kumar Kedia & Shri Vimal Kumar

Section 12ASection 13(1)(c)Section 2(15)Section 80GSection 80G(5)

…above documents in the impugned order. The appellant/applicant had prayed for restoration of the matter for fresh adjudication. Hon’ble Supreme Court of India in the case of Ananda 9. Social & Educational Trust vs Commissioner of Income Tax Page4 reported in 426 ITR 340 (SC) has held as under :- Ekal Gramothan-ITA 322 & 323 “12. Since section 12AA pertains to the registration of the Trust and not to assess of what a trust has actually done, we are of the view that the term ‘activities’ in the provision includes ‘proposed activities’. That is to say, a Commissioner is bound to consider whether the objects of th…

Pr. Commissioner of Income Tax vs. Smt. Pallavi Mishra

ITA/10/2022HC Rajasthan14 Nov 2024

Bench: AVNEESH JHINGAN,UMA SHANKER VYAS

Section 12Section 12ASection 260A

…s to pass an order in writing registering the trust or institution and a copy of the order so passed will be sent to the applicant. 8. The Supreme Court in the matter of Ananda Social and Educational Trust v. Commissioner of Income Tax and another, (2020) 17 SCC 254 held that newly registered trust on basis of its objects, without any activity having been undertaken, is entitled for registration under Section 12AA of the Act, and observed as under: - “9. Section 12-AA undoubtedly requires the Commissioner to satisfy himself about the objects of the trust or institution and genuineness of its activities a…

Shri Ram Darbar Sewak Pariwar Dharmarth Trust, Hisar vs. CIT (Exemptions), Chandigarh

The appeal of the assessee is allowed for statistical purpose

ITA 1515/DEL/2024[2024-25]Status: DisposedITAT Delhi11 Sept 2024AY 2024-25

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 12ASection 12A(1)(ac)Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Shri Ram Darbar Sewak CIT(Exemption) Pariwar Dharmarth Chandigarh Trust, Vs. House No.7, Kailashwati, Bhawan, Gali Nalbandh, City Thana Road, Hisar, Haryana-125001 PAN:AAXRS6432R (Appellant) (Respondent) Assessee by Shri Suraj Bhan Nain, Adv. Mr. Mahfuzur Rahman, Adv. Respondent by Shri Sujit Kumar, CIT- DR Date of Hearing 06/08/2024 Date of Pronouncement 11/09/2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal of the Assessee arises out of order of the Lea…

Shrionkar Singh Memorial Trust, Delhi vs. CIT (Exemption), New Delhi

The appeal of the assessee is allowed for statistical purpose

ITA 1750/DEL/2024[NA]Status: DisposedITAT Delhi28 Aug 2024

Bench: 12/03/2024 Was Issued. The Appellant/Applicant Uploaded Certain Details & Documents On 12/03/2024. Reply Was Also Submitted By Appellant Vide Letter Dated 12/3/2024 & Requested To Submit The Documents & Clarifications.

Section 12ASection 12A(1)(ac)Section 2(15)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Shrionkar Singh The CIT(Exemptions) Memorial Trust New Delhi-10002 B-12, NBT Apartments Vs. Mayur Vihar, Phase-I Delhi-110091 PAN:AACTS 6795G (Appellant) (Respondent) Assessee by Shri V. Raja Kumar, Adv. Respondent by Shri Dharam Veer Singh, CIT- DR Date of Hearing 13/08/2024 Date of Pronouncement 28/08/2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal of the Assessee arises out of order of the Learned Commissioner of Income Tax (Exemptions), Chandigarh, […

Seth Panna Lal Charitable Trust, Karnal vs. CIT (Exemption), Chandigarh

The appeal of the assessee is allowed for statistical purposes

ITA 1642/DEL/2024[N.A.]Status: DisposedITAT Delhi28 Aug 2024

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 12ASection 12A(1)(ac)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Seth Panna Lal CIT(Exemptions) Charitable Trust Chandigarh 90, New Grain Market Vs. Taraori Karnal Haryana-132001 PAN:AAYTS 8601B (Appellant) (Respondent) Assessee by Shri Ved Jain, Adv. & Shri Aman Garg, Adv. Respondent by Shri Dharm Veer Singh, CIT-DR Date of Hearing 14/08/2024 Date of Pronouncement 28/08/2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal of the Assessee arises out of order of the Learned Commissioner of Income Tax (Exemptions), Chandigarh…

Xander India Foundation, Delhi vs. CIT( Exemption), Delhi

In the result, the appeals of the assessees are allowed for statistical purpose

ITA 2736/DEL/2024[NA]Status: DisposedITAT Delhi22 Aug 2024

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumar

For Appellant: Sh. Gaurav Singhal, Adv. &For Respondent: Ms. Monika Dhami, CIT-DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Sudhir Kumar, Judicial Member ITA No. 2734/Del/2024 Yuj Arts Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AABCY6026A ITA No. 2736/Del/2024 Xander India Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AAACX4257H Assessee by : Sh. Gaurav Singhal, Adv. & Ms. Abha Kamra, Adv. Revenue by : Ms. Monika Dhami, CIT-DR Date of Hear…

Xander India Foundation, Delhi vs. CIT Exemption, Delhi

In the result, the appeals of the assessees are allowed for statistical purpose

ITA 2735/DEL/2024[-]Status: DisposedITAT Delhi22 Aug 2024

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumar

For Appellant: Sh. Gaurav Singhal, Adv. &For Respondent: Ms. Monika Dhami, CIT-DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Sudhir Kumar, Judicial Member ITA No. 2734/Del/2024 Yuj Arts Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AABCY6026A ITA No. 2736/Del/2024 Xander India Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AAACX4257H Assessee by : Sh. Gaurav Singhal, Adv. & Ms. Abha Kamra, Adv. Revenue by : Ms. Monika Dhami, CIT-DR Date of Hear…

Yuj Arts Foundation, Delhi vs. CIT Exemption, New Delhi

In the result, the appeals of the assessees are allowed for statistical purpose

ITA 2734/DEL/2024[-]Status: DisposedITAT Delhi22 Aug 2024

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumar

For Appellant: Sh. Gaurav Singhal, Adv. &For Respondent: Ms. Monika Dhami, CIT-DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Sudhir Kumar, Judicial Member ITA No. 2734/Del/2024 Yuj Arts Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AABCY6026A ITA No. 2736/Del/2024 Xander India Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AAACX4257H Assessee by : Sh. Gaurav Singhal, Adv. & Ms. Abha Kamra, Adv. Revenue by : Ms. Monika Dhami, CIT-DR Date of Hear…

Yuj Arts Foundation, Delhi vs. CIT Exemption, Delhi

In the result, the appeals of the assessees are allowed for statistical purpose

ITA 2733/DEL/2024[-]Status: DisposedITAT Delhi22 Aug 2024

Bench: Dr. B. R. R. Kumarsh. Sudhir Kumar

For Appellant: Sh. Gaurav Singhal, Adv. &For Respondent: Ms. Monika Dhami, CIT-DR

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Sudhir Kumar, Judicial Member ITA No. 2734/Del/2024 Yuj Arts Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AABCY6026A ITA No. 2736/Del/2024 Xander India Foundation, Vs CIT(Exemption), H-26A, 2nd Floor, Kalkaji, Nehrau Place, New Dehi-110002 New Delhi-110019 (APPELLANT) (RESPONDENT) PAN No. AAACX4257H Assessee by : Sh. Gaurav Singhal, Adv. & Ms. Abha Kamra, Adv. Revenue by : Ms. Monika Dhami, CIT-DR Date of Hear…

Sant Shiromani Namdev Charitable Trust, Jhajjar vs. CIT (Exemptions), Chandigarh

In the result, appeal is allowed for statistical purpose

ITA 1718/DEL/2024[2023-24]Status: DisposedITAT Delhi13 Aug 2024AY 2023-24

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI VIMAL KUMAR (Judicial Member)

Section 12ASection 12A(1)(ac)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER Sant Shiromani Namdev CIT(Exemptions) Charitable Trust Purani Chandigarh Tehsil Road, Adarsh Vs. Nagar, Jhajjar Haryana PAN:AALTS7875C (Appellant) (Respondent) Assessee by Shri Naveen Gupta, Adv. Respondent by Shri Dharam Veer Singh, CIT- DR Date of Hearing 13/08/2024 Date of Pronouncement 13/08/2024 O R D E R PER VIMAL KUMAR, JM: 1. The appeal of the Assessee arises out of order of the Learned Commissioner of Income Tax (Exemptions), Chandigarh, [hereinaf…

Sansthanam Abhay Daanam, Nandurbar vs. CIT (Exemption), Pune

In the result, the appeal of the assessee in ITA No

ITA 950/PUN/2023[Not Applicable]Status: DisposedITAT Pune24 Jul 2024

Bench: Shri Inturi Rama Rao & Ms. Astha Chandra

For Appellant: Shri P.S. ShingteFor Respondent: Shri Abhay Kumar Keshari
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

…Damodardas Lohia Charitable Trust Vs. Director of Income-tax (Exemptions) (2015) 44 ITR (T) 161 (Hyderabad-Trib.); VI. Vanita Vishram Trust Vs. Chief Commissioner of Income-tax (2010) 327 ITR 121 (Bombay); VII. Ananda Social & Educational Trust Vs. CIT (2020) 426 ITR 340 (SC); VIII. CIT (Exemptions) Vs. Jagannath Gupta Family Trust (2019) 411 ITR 235 (SC). 17. The Ld. DR supported the order of the Ld. CIT(E). 18. We have considered the submission of the parties and perused the records. It is not in dispute that in response to notice dated 14.03.2023 issued by the Ld. CIT(E), the assessee furnished reply on 21.03…

Sansthanam Abhay Daanam, Nandurbar vs. CIT (Exemption), Pune

In the result, the appeal of the assessee in ITA No

ITA 949/PUN/2023[NOT APPLICABLE]Status: DisposedITAT Pune24 Jul 2024

Bench: Shri Inturi Rama Rao & Ms. Astha Chandra

For Appellant: Shri P.S. ShingteFor Respondent: Shri Abhay Kumar Keshari
Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)

…Damodardas Lohia Charitable Trust Vs. Director of Income-tax (Exemptions) (2015) 44 ITR (T) 161 (Hyderabad-Trib.); VI. Vanita Vishram Trust Vs. Chief Commissioner of Income-tax (2010) 327 ITR 121 (Bombay); VII. Ananda Social & Educational Trust Vs. CIT (2020) 426 ITR 340 (SC); VIII. CIT (Exemptions) Vs. Jagannath Gupta Family Trust (2019) 411 ITR 235 (SC). 17. The Ld. DR supported the order of the Ld. CIT(E). 18. We have considered the submission of the parties and perused the records. It is not in dispute that in response to notice dated 14.03.2023 issued by the Ld. CIT(E), the assessee furnished reply on 21.03…

Shree Munisuvrat Swami Gangadham Tower Jain Sangh, Pune vs. Commissioner of Income Tax (Exemption), Pune

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 166/PUN/2024[-]Status: DisposedITAT Pune15 Jul 2024

Bench: Shri Rama Kanta Panda & Ms. Astha Chandra

For Appellant: Smt. Deepa KhareFor Respondent: Shri Pankaj Kumar
Section 12ASection 12A(1)(ac)

…ed/appreciated by the Ld. CIT(E) who held that application for registration is non-maintainable as the trust has not commenced its activities. Relying on the decision of the Hon’ble Supreme Court in the case of Ananda Social & Educational Trust Vs. CIT (2020) 426 ITR 340 3 (SC), the Ld. AR argued that the matter may be sent to the Ld. CIT(E) so that the assessee may explain its case to him. 5. The Ld. DR supported the order of Ld. CIT(E) relying on the decision of the Hon’ble Kerala High Court in the case of Self Employers Service Society Vs. CIT (2000) 113 Taxman 703 (Kerala) and the decision of Cochin Bench o…

Karamshi Jethabhai Somaiya (Delhi) Trust, Delhi vs. Circle Exempt 1(1), Delhi

The appeals of the assessee are allowed

ITA 3354/DEL/2023[2023-24]Status: DisposedITAT Delhi02 Jul 2024AY 2023-24

Bench: Shri M Balaganesh & Shri Vimal Kumar

For Appellant: Shri K Gopal, AdvocateFor Respondent: Shri Sanjay Kumar, CIT(DR)
Section 12A(1)(ac)Section 2(15)Section 80G(5)

…hree Girivanavasi Pragati Mandal Receipt No. 734 dated 15.02.2021 for Rs. 26,00,000/- 8. Learned authorised representative submitted that Hon’ble Supreme Court of India in the case of Ananda Social & Educational Trust vs Commissioner of Income Tax reported in 426 ITR 340 (SC) has held as under :- “12. Since section 12AA pertains to the registration of the Trust and not to assess of what a trust has actually done, we are of the view that the term ‘activities’ in the provision includes ‘proposed activities’. That is to say, a Commissioner is bound to consider whether the objects of the Trust are genuinely charitabl…

Karamshi Jethabhai Somaiya (Delhi) Trust, Delhi vs. Circle Exempt 1(1), Delhi, New Delhi

The appeals of the assessee are allowed

ITA 3353/DEL/2023[2023-24]Status: DisposedITAT Delhi02 Jul 2024AY 2023-24

Bench: Shri M Balaganesh & Shri Vimal Kumar

For Appellant: Shri K Gopal, AdvocateFor Respondent: Shri Sanjay Kumar, CIT(DR)
Section 12A(1)(ac)Section 2(15)Section 80G(5)

…hree Girivanavasi Pragati Mandal Receipt No. 734 dated 15.02.2021 for Rs. 26,00,000/- 8. Learned authorised representative submitted that Hon’ble Supreme Court of India in the case of Ananda Social & Educational Trust vs Commissioner of Income Tax reported in 426 ITR 340 (SC) has held as under :- “12. Since section 12AA pertains to the registration of the Trust and not to assess of what a trust has actually done, we are of the view that the term ‘activities’ in the provision includes ‘proposed activities’. That is to say, a Commissioner is bound to consider whether the objects of the Trust are genuinely charitabl…

CIT (Exemption), Kolkata vs. Harnarayan Rajdulari Devi Taparia - Charitabale Trust

ITA/111/2019HC Calcutta01 Jul 2024

Bench: : The Hon’Ble Justice Surya Prakash Kesarwani

Section 12ASection 12A(1)Section 2Section 2(15)Section 80G

…10 (Exemption), Bangalore Etc. Vs. Meenakshi Amma Endowment Trust Etc.) holding as under: “Delay condoned. In view of the judgment of this Court in 'Ananda Social And Educational Trust v. Commissioner of Income Tax and Another', [(2020) 17 SCC 254], which judgment has approved the view taken by the Delhi High Court in 'Director of Income Tax v. Foundation of Ophthalmic & Optometry Research Education Centre' [(2013) 355 ITR 361], the question of law raised in these matters has to be answered against the Revenue and in favour of the assessee. Accordingly, the appeals and the specia…

Parmeshwar Param Seva Foundation, Nashik vs. Commissioner of Income Tax (Exemption), Pune

In the result, the appeal filed by the appellant is allowed

ITA 1358/PUN/2023[-]Status: DisposedITAT Pune20 Jun 2024

Bench: Shri Satbeer Singh Godara & Shri Inturi Rama Raoआयकर अपील सं. / Ita No.1358/Pun/2023

For Appellant: Shri Sanket JoshiFor Respondent: Shri P.R. Mane
Section 12ASection 12A(1)(ac)

…nce of the charitable in nature i.e. satisfy himself about the genuineness of the activities carried on by the assessee as held by the Hon’ble Supreme Court in the case of Ananda Social and Educational Trust Vs. CIT [2020] 114 taxmann.com 693/272 Taxman 7/ 3 426 ITR 340/[2020] 17 SCC 254. The relevant para of the judgment is reproduced below : "Since section 12AA pertains to the registration of the Trust and not to assess of what a trust has actually done, we are of the view that the term 'activities' in the provision includes 'proposed activities'. That is to say, a Commissioner is bound to consider whether th…

Disha Education Society, Raipur vs. Commissioner of Income Tax, Exemption, Bhopal

In the result, both appeals of assessee are allowed

ITA 165/IND/2023[00]Status: DisposedITAT Indore22 Nov 2023

Bench: Shri Vijay Pal Rao & Shri B.M. Biyani

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)Section 80G(5)(ix)

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER ITA No.164 & 165/Ind/2023 (Assessment Years:---) Disha Education CIT(Exemption) Society Bhopal Vs. 574/50, Disha Towers, Raipur (Appellant / Assessee) (Revenue) PAN: AAATD 5249C Appellant by Shri Sumit Nema, Sr. Adv. & Gagan Tiwari, AR Revenue by Ms. Simran Bhullar, CIT-DR Date of Hearing 02.11.2023 Date of Pronouncement 22.11.2023 O R D E R Per Vijay Pal Rao, JM: These two appeals by the Assessee are directed against the composite…

Samarpan Annam Danam Charitable Society, Gwalior vs. CIT(Exemption), Bhopal

In the result, the Appeal of the assessee is allowed

ITA 186/AGR/2022[00]Status: DisposedITAT Agra11 Aug 2023
Section 12Section 12ASection 2(15)

…rpan Annam Danam Charitable society Vs. CIT (E) which have not been considered by the CIT(E). In our opinion, starting only one activity out of many may not be or a bar for registration so long that activity is charitable. Reliance placed on S.C decision in 426 ITR 340 at 355 wherein it is held as under:- “The above section provides for registration of a trust. Such registration can be applied for by a trust which has been in existence for some time and also by a newly registered trust. There is no stipulation that the trust should have already been in existence and should have undertaken any activities befor…

M/S M/S Shri Agrasen Jan Kalyan Trust, Raigarh(Cg) vs. The Commissioner of Income Tax(Excemption), Bhopal

In the result, the appeal of assessee allowed

ITA 334/BIL/2016[2016-17]Status: DisposedITAT Raipur04 Jul 2023AY 2016-17

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.334/Rpr/2016 (धििाारण िर्ा / Assessment Year :2016-2017) M/S Shri Agrasen Jan Kalyan Trust Vs Cit(Exemption), Bhopal At/Po: Kharsia Pan No. : Aaets 9269 H (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) धििााररती की ओर से /Assessee By : Shri G.S.Agrawal, Ca राजस्ि की ओर से /Revenue By : Shri V.K.Singh, Cit-Dr सुििाई की तारीख / Date Of Hearing : 25/04/2023 घोर्णा की तारीख/Date Of Pronouncement : 04/07/2023 आदेश / O R D E R Per Arun Khodpia, Am :

For Appellant: Shri G.S.Agrawal, CAFor Respondent: Shri V.K.Singh, CIT-DR
Section 12A

…stead the objects of the trust should have been the basis that whether the same are genuinely charitable in nature or not?, on this aspect Ld AR of the assessee relied on the judgment in the case of Ananda Social & Educational Trust V. CIT, reported in [2020] 426 ITR 340 (SC)[19-02- 2020], wherein Hon’ble apex court has held as under:- 12. Since section 12AA pertains to the registration of the Trust and not to assess of what a trust has actually done, we are of the view that the term 'activities' in the provision includes 'proposed activities'. That is to say, a Commissioner is bound to consider whether the objec…