Mysore Brindavan Sky Trust Vs CIT (Exemptions) (ITAT Bangalore)
Assessee is a charitable Trust promoting Yoga Practices founded on 01.01.2009, as the Trust intended to expand its activities applied for Registration u/s 12AB as per Form 10AB e-filed. CIT(E) noted that Assessee has made minimal amount of expenditure towards the object of the Trust & no expenditure has been debited from bank account. Further, the fees received for various yoga programs does not match with the income as per the financial statements. CIT(E) thus ruled that assessee has not commenced its activities towards attainment of the objects & hence the application filed for registration was rejected.
Before the Tribunal Assessee claimed that it has submitted the complete details before CIT(E) & that income from yoga classes for multiple years (₹67,000 in FY 2021–22, ₹1.17 lakh in 2022–23, ₹4.53 lakh in 2023–24). Therefore, it is not correct to state that Assessee has not started the activities of the Trust. He further referred to his application of the Trust stating that complete details about the activities of the trust was also produced before CIT(E) along with the details of assets & liability & therefore it is not proper to hold that Assessee has not commenced its activities & therefore rejection of such application is not correct.
