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The Ld. Further in Para 14 mentioned that the assessee has received loans from various persons. All the creditors are Income Tax assessee's and have substantial capital and substantial Income. The remark that unexplained credits are not proved is totally contrary to the evidence on record. In any case the loans have been utilized for the objects of the trust and there is no infringement of any of the provisions of the Income Tax law.

Submissions of the Assessee:-

The assessee is a charitable Society and doing the activity of education. The objects of the assessee Society are purely charitable and there is no distribution of any profit to anyone. The Society has been granted registration u/s 12A/12AA by the Ld. CIT after scrutinizing the accounts and verifying the objects of the Society. There is no change in the object clause since the inception. The activity of the education is being undertaken since inception and is continuing till to date. The Society has not infringed any of the provisions of section 11 to 13. The funds including the borrowed funds have been utilized for the objects of the trust. The trust has not given any advance in contravention to provision of section 13. The advances have been given to the charitable trusts which are registered u/s 12AA. Giving the financial assistance to charitable colleges is one of the objects of the trust.

The arrangement between the trustees for management is not adverse to the charitable object and it is between the trustees and not between the assessee societies. The assessee Society has received donations to the corpus fund and has not distributed any fund to anybody; it has utilized all the funds for Sardar Harman Singh Keer Public Welfare trust the charitable objects of the Society. Thus the conclusion drawn by the Ld. A.O and the Ld. CIT about the genuineness of the activity are perverse and contrary to the fact on record. The rejection of the registration is thus bad in law and without jurisdiction.