In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
147 has not made any allegation regarding activities of the assessee trust and assessing officer has been satisfied that assessee is an charitable institute and its activities are charitable activities within the ambit of provisions of section 2(15) of Income Tax Act, 1961. 4.3 As regards the allegation of Ld. AO. that assessee has made contravention of provisions