JUDGMENT

Sanjeev Narula, J. (Oral) - The Commissioner of Income Tax - Exemption has filed the present appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as "the Act") assailing the order dated 19.04.2018 passed by the Income Tax Appellate Tribunal (hereinafter referred to as the ''ITAT''). The present appeal proposes substantial questions of law, questioning the correctness of the findings of ITAT in relation to the activities of the assessee in the context of eligibility to get registration as a charitable organization under Section 12AA of the Act.

2. The Respondent-Association of Third Party Administrators (ATPA) filed an application on 12.12.2005 seeking registration under Section 12A of the Act. The said application was rejected by DIT(E), vide order dated 30.06.2006 holding that certain objects of the trust were not charitable and trustees had discretion in applying the trust''s income to any of the objects. Aggrieved with the aforesaid findings, assessee filed an appeal before IT AT which resulted in order dated 30.04.2017, restoring the matter to the file of DIT(E) with direction to pass a speaking order as to which of the objects were of non-char