alleged
ground of non-submission of certain documents, whereas the appellant
trust had duly submitted all relevant documents and clarifications as
sought by the department ... erred in rejecting the application merely on
technical grounds such as missing documents or procedural aspects,
whereas the substantive compliance and charitable nature
alleged
ground of non-submission of certain documents, whereas the appellant
trust had duly submitted all relevant documents and clarifications as
sought by the department ... erred in rejecting the application merely on
technical grounds such as missing documents or procedural aspects,
whereas the substantive compliance and charitable nature
sustainable due to the lack of specific mention of missing documents
without appreciating the fact that the TPO had clearly brought on
record the specifics ... missing documents/information in her order
under section 92CA(3) of the Act, more specifically in paragraphs
7.3,7.5.2, 10 and 18 of the said
sustainable due to the lack of specific mention of missing documents
without appreciating the fact that the TPO had clearly brought on
record the specifics ... missing documents/information in her order
under section 92CA(3) of the Act, more specifically in paragraphs
7.3,7.5.2, 10 and 18 of the said
copy
of FIR filed with the Shivaji Nagar Police Chowki regarding missing document
of the assessee i.e. 12A registration certificate No.1845. The said ... Pune. Through these documents, the Ld.AR of the
assessee demonstrated that they have fairly intimated and informed the
Department regarding missing of 12A registration
under RTI.
m. Thus the whole order is based on incorrect/missing
facts/documents.
11
MA.No.282/PUN./2023
3. In view
Shri Brijendra Nath Agarwal
for the assessee further referred to the seized documents from the premises of
CIIL and points out that in respect ... that list of cheque payments, name of assessee is
missing. Further, on the said document itself, there is cash payment of ₹ 15
lakhs, which also
proposition that a document will be a dumb
document, where any of the above four ingredients is missing and
AO fails fill
could be used only against the person from whose
premises the documents are found and not against the person whose name appears
in the seized ... assessee since no incriminating documents were found with it. In
the case of ACIT Vs. Lata Mangeshkar (Miss) (1974) 97 ITR 696 (Bom), the
addition
could be used only against the person from whose
premises the documents are found and not against the person whose name appears
in the seized ... assessee since no incriminating documents were found with it. In
the case of ACIT Vs. Lata Mangeshkar (Miss) (1974) 97 ITR 696 (Bom), the
addition
