premise that
the activities of the trust were rendered non-genuine. The Learned AR before
us vehemently argued that the show-cause notice ... 12AB. (1) to (3) .................
(4) Where registration or provisional registration of a trust or an institution has
been granted under clause (a) or clause
found to be non-genuine or are not being carried out in
accordance with the objects of the trust, its registration granted can
become liable ... funds is
stated to be non-genuine. In such cases it would not make the
whole Trust Non genuine. For This proposition
charitable purposes,
can be regarded as non-genuine or contrary to the objects for which the
assessee trust was formed. There is also merit ... charitable purposes,
can be regarded as non-genuine or contrary to the objects for which the
assessee trust was formed. There is also merit
extends only to the satisfaction of the genuineness of the activity of
such trust and the fulfillment of all the conditions laid down to clause ... even whisper
about any activity of the trust to be non-genuine. It is also not the
case of the ld. CIT (Exemption) that
held to be a
non-genuine activity or activity being carried out contrary to the objects
of a Trust. The Ld. AR submitted that ... charitable purposes,
can be regarded as non-genuine or contrary to the objects for which the
assessee trust was formed. There is also merit
other related institutions run by M/s. Meenakshi Ammal Trust and Sri
Muthukumaran Educational Trust have been duly recorded and
substantiated with relevant documentation ... deposits
were from unaccounted or non-genuine sources. The AO based upon the
bank statements of the appellant trust has arrived at a conclusion that
applied, other than for
the objects of the trust or institution.
b. The trust or institution shall not have income from profits and gains ... particular religious community or
caste.
f. No non-genuine activity shall be earned out by the trust or institution.
g. No such activity shall
applied, other than for
the objects of the trust or institution.
b. The trust or institution shall not have income from profits and gains ... particular religious community or
caste.
f. No non-genuine activity shall be earned out by the trust or institution.
g. No such activity shall
That the learned CIT (Exemptions) erred in presuming that activities
were not genuine merely due to lack of bill/invoice copies or technical
mismatches with ... satisfaction of the twin conditions
of (i) non-genuineness and (ii) non-compliance with objects of the trust.
12. That the order passed is contrary
inter-institutional
transfers within the trust. The appellant explained that transfers were made
between different institutions under the trust for various operational
purposes. For instance ... deposits
were from unaccounted or non-genuine sources. The AO based upon the
bank statements of the appellant trust has arrived at a conclusion that
