ITAT AMRITSAR BENCH
Dream Land Educational Trust
v.
Commissioner of Income-tax, J&K, Jammu
JOGINDER PALL, ACCOUNTANT MEMBER
AND A.D. JAIN, JUDICIAL MEMBER
IT APPEAL NO. 481 (ASR.) OF 2005
APRIL 5, 2007
Section
12AA, read with section 12A, of the Income-tax Act, 1961 - Charitable or
religious trust - Registration procedure - Whether for grant of registration
under section 12AA, only relevant consideration is satisfaction of Commissioner
regarding objects of trust and genuineness of its activities - Held, yes
Facts
A partnership firm
consisting of two partners was running an educational institution. The said
firm was dissolved vide a dissolution deed. The assessee-trust took over
the properties/assets and liabilities from the erstwhile firm on its
dissolution. Two of the trustees of the assessee-trust were erstwhile partners
of the dissolved firm. The assessee-trust applied for registration under
section 12A(a). The Commissioner, however, denied the registration on
various grounds.
On appeal :
Held
Section
12AA prescribes the procedure for registration of a trust. As per this section,
the Commissioner, on receipt of an application for registration, shall call for
such documents or information for the trust as he thinks necessary in order to
satisfy himself about the genuineness of the trust and may also make such
enquiry as he may deem necessary in this behalf; and that after satisfying
himself about the objects of the trust and the genuineness of its activities,
he shall pass an order in writing, registering the trust. Therefore, in
accordance with section 12AA, the Commissioner was required to satisfy himself
about the objects of the trust and the genuineness of its activities. In the
instant case, the Commissioner had not recorded any dissatisfaction on either
of these two aspects. The first issue raised by the Commissioner was with
regard to the registration of the dissolution deed of the firm. The erstwhile
firm, having two partners, which were the trustees of the assessee-trust, was
dissolved vide a
dissolution deed. The Commissioner had objected that this dissolution deed was
not registered but was simply attested by a Notary having no value under the
provisions of the Transfer of Property Act. Such observation had no relation
whatsoever with either the objects of the trust or its activities. Moreover,
the dissolution deed had not been shown to be required to be registered for the
purposes of granting of registration to the assessee-trust. The observations of
the Commissioner in this regard were, therefore, not in any way detrimental to
the assessee’s claim of registration.
The
Commissioner had further observed that no transfer deed stood executed
regarding the property taken over by the trust from the erstwhile firm on its
dissolution. Again, this had no bearing on the satisfaction of the Commissioner
with regard to the objects of the trust or its activities. Further, it had been
argued and not rebutted that the trustees of the trust were the erstwhile
partners of the dissolved firm and, therefore, no transfer deed was thought required
to be executed on the take over of the property of the erstwhile firm by the
assessee-trust. Also, Schedule ‘A’ forming part of the Trust Deed reflected the
properties and assets transferred to the trust by its settlors who were the
partners of the erstwhile firm. As per this Schedule, the settlors had only
given the properties to the trust and nothing had been taken. Anyhow, the
observations of the Commissioner in this regard were, again, not observations
adverse to the satisfaction of the Commissioner either regarding the objects of
the trust or the genuineness of its activities.
The next
observation of the Commissioner was with regard to the take over action being
unilateral. In the view of the Commissioner, since the transfer of the property
of the trust was not through a duly executed transfer deed, even if the two
partners of the erstwhile firm did not object to the take over of the firm,
they could, at any future point of time, claim their property from the trust,
thereby jeopardizing the functioning of the trust and its objects. This
observation, besides having no connection with the satisfaction of the
Commissioner with regard to the objects of the trust and its activities, was an
observation based on pure conjecture. This observation, as such, had no effect
adverse to the registration of the trust.
The
Commissioner had further observed that since no objection certificate was
obtained from the bankers, the apprehension of any future action by the
partners of the erstwhile firm or the financiers thereof, regarding claiming
back the property from the trust, was entirely realistic. Again, this
observation had no bearing on the registration of the assessee-trust. Under
section 12AA, the Commissioner was only required to satisfy himself with regard
to the objects and genuineness of the activities of the trust. The observation
under consideration did not at all impinge upon either of these aspects. Again,
this observation was the result of merely surmises and conjectures. Nothing
turned on it against the assessee qua registration.
Lastly, the
Commissioner had observed that as per the trust deed, on dissolution of the
firm, it had been left to the trustees to decide the fate of the net assets. It
had been observed that while registering a trust, safeguards regarding the fate
of the trust were to be considered very minutely ; that no trust, the
application of whose assets and income was possible to objects other than those
envisaged, could be registered ; and that whereas, in the instant case, the
trustees had been left to decide the fate of the net assets were irrelevant.
The settlors of the trust were trustees for life. The trust was irrevocable.
The provisions of the trust deed were only enabling clauses. Moreover, the
observations of the Commissioner were with regard to only some hypothetical
impending assumed revocation of the trust. These observations lie entirely in
the realm of conjecture and registration had wrongly been refused on the basis
thereof.
That apart,
the objects of the trust, as defined in the trust deed, were laid bare before
the Commissioner, who did not find anything offensive therein.
The
Commissioner had not observed any of the objects of the assessee-trust, as
defined in the trust deed, to be not to his satisfaction. None of these objects
had been stated to be outside the purview of section 2(15). Further, the balance sheet of the
assessee-trust, as on 31-3-2005 showed that all the income earned by the trust
had been invested in the trust only. Further, the Commissioner, had not, anywhere
in the impugned order, doubted either the genuineness of the activities of the
trust, or its objects. It had not been stated that any object of the trust was
not that of charity or that the income of the trust had been used for the
purpose of the trustees or their families and had not been utilized for
charity.
In these
circumstances, in the absence of any dissatisfaction of the Commissioner with
regard to either the objects or the genuineness of the activities of the trust,
registration had been refused to the trust in violation of the provisions of
section 12AA. The reasons recorded for such rejection of registration were
entirely extraneously to the requirement of the said section.
Various
decisions of the Tribunal propounded that for grant of registration under
section 12AA, the only relevant consideration is the satisfaction of the
Commissioner regarding the objects of the trust and the genuineness of its
activities.
In view of
the above, the grievance of the assessee was entirely justified and was accepted
as such.
In the
result, the appeal of the assessee was to be allowed.