Meera-Twinkle Sevabhavi Sanstha Vs CIT (ITAT Pune)
Assessee, a registered public trust, sought 12A registration to carry out charitable activities such as providing legal aid & rehabilitation for victims of large-scale financial fraud perpetrated by the Citrus Group, which had duped several poor & illiterate investors. The trust argued that helping victims obtain justice through legal support & awareness fell squarely within “advancement of any other object of general public utility” u/s 2(15).
CIT(E), however, rejected the application holding that the activities were confined to a specific group of Citrus investors, unrelated to the stated objects like education or medical aid, & hence not charitable. He also cited cancellation of earlier provisional registration & alleged lack of evidence of charitable expenditure. He further stated that physical or virtual hearing was not required since compliance could be done online.
Before Tribunal, the Assessee argued that its activities were genuinely charitable, intended to assist vulnerable sections defrauded by a ₹8,000-crore scam, evidenced by SEBI orders, Supreme Court supervision, & recovery proceedings. It was also submitted that the request for virtual hearing was ignored by CIT(E), depriving the Trust of fair opportunity. The Bench noted from the record that such request was indeed made & denied, a fact even admitted in para 6.6 of the CIT(E)’s order.
