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3. We find that our view is fortified by the judgment of the Hon'ble Allahabad High Court reported in (1990) 185 ITR 634 wherein it was held that "3. It is evident that at this stage, the Commissioner is not to examine the application of income. All that he may examine is whether the application is made in accordance with the requirements of section 12A read with rule 17A and whether Form 10A has been properly filled up. He may also see whether the objects of the trust are charitable or not At this stage, it is not proper to examine the application of income.

9. In the result, the appeal of the assessee in ITA No.943/PUN/2019 is allowed.

10. With regard to ITA No.944/PUN/2019, in respect of application for exemption u/s 80G(5)(vi) of the Act, it is evident at Para 4 of the ld. CIT(Exemption) in his order that as being asked to upload various details in ITBA Portal, the assessee trust has not uploaded / submitted any evidence i.e., school permission letter, fees, salary structure, details of expenditure incurred to run primary and secondary schools and utilization of income from property held under trust towards charitable objects of the trust. That further at Para 5 of the order of ld. CIT(Exemption) observes that the application of the assessee trust cannot be processed as no verifiable details / proof have been furnished to substantiate the genuineness of the charitable activities of the trust. Thus, the assessee has failed to prove necessary documents required by Rule 11AA(2)(ii) of the Income Tax Rules 1962, and hence, the exemption under Sec.80G(5)(vi) of the Act was rejected.