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3. The brief facts of the case are that the Commissioner of Income Tax (Exemption), observed that Clause (xv) of the Trust Deed reads as under:

"(xv) "To publish and or publishing books, pamphlets, periodicals and newspapers, journals, magazines, course materials in India or outside for the recognition of education and culture."

4. A reading of the same shows that the assessee intends to carry out its activities outside India, whish is contrary to the provisions of section 11(1)(a) of the Act and, therefore, is not eligible for registration u/s.12AA of the Act. He further observed that the assessee has not filed his income and expenditure account and thus, violated the Rule 17A of Income tax Rules. He also observed that some of the basic clauses such as beneficiary clause, dissolution clause, irrevocability clause, etc are not incorporated in the trust deed. Therefore, he rejected the grant of registration under section 12AA of the Act to the assessee and consequently, rejected the grant of approval u/s.80G of the Act.

11. Ld Departmental Representative could not controvert the submission of ld Authorised Representative of the assessee.

12. We have heard the rival submissions, perused the orders of lower authorities and materials available on record. In the instant case, application for registration under section 12AA of the Act was rejected by the CIT( Exemptions) on the ground that Cl. No.

(xv) of the trust deed empowers the trustee to carry on activities outside India which is in violation of section 11(1)(a) of the Act and the trust deed does not provide what will happen to trust property on dissolution of the trust and as well as the trust deed does not provide that the benefit shall be conferred without any discrimination on the basis of caste, creed and religion.