section 12AA of the Act on the ground that
objects of the trust are both charitable and religious activities.
3. The Departmental Representative relied ... Trust. Therefore, the
5 ITA No.14/Mds/2013
said provision would be applicable to both the Trusts
established with the object of charitable
failed to discharge the onus of proving the
charitable/religious nature of the objects of the trust and
genuineness of the activities carried ... many steps to be followed before finally accomplishing the
objectives of a charitable trust. It is not possible to expect that the
assessee trust should
objects of the trust
and activities being carried out by the trust. If the objects of
the trust are charitable in nature and the activities ... assessee trust
has amended its objects in violation of the provisions of the
Indian Trust Act. Once the trust has been created, its objects
cannot
object clauses of the trust
deed to contend that clauses a, c, d and e of the Object
Clause of the Trust deed ... further the attainment of the objects of the trust."
A perusal of the object clauses show that the trust is being
created
opinion that the Trusts
had not done any worthwhile charitable activities. According to CIT,
the Trusts had objects, which were admixture of both religion ... assessee-Trust could be both religious
as well as charitable Trust and just because objects were both
religious and charitable, registration under Section 12AA could
trust deed shows that the trust has been
2 ITA No.74/Mds/2013
constituted as charitable and religious trust with the following
objects ... objects of the trust clearly shows that the trust
has been formed primarily with the objects of carrying on
charitable activities. The order
Trust
had donated a sum of ` 1 lakh to another Trust. Thereafter the latter
Trust donated certain sums back to the former Trust ... Champa Charitable Trust (supra), Hon'ble
Bombay High Court has held that when a Trust receives donation
from another Trust, and such donations were
doubt, the association was established as
a charitable association and carrying on charitable activities
and at the same time, it appears that the assessee ... assessee were to the other charitable organizations which
were registered under section 12A and having similar objects.
We find that the co-ordinate Bench
cent of the income of a
charitable and religious trust to be applied for religious and charitable
purposes to be entitled to the exemption under ... fulfill one of the objects of the trust will amount to an application
of the income for charitable and religious purposes. As regards the
loans
that assessee is a public charitable Trust
created under a deed of Trust by one Smt. V. Krishnaveni Ammal.
Objects of the Trust ... 2010
mentioned that objects (e),(f),(g), & (h) are incidental to objects
mentioned at (a),(b),(c) & (d). Nevertheless, objects mentioned