Sanjay K. Agrawal, J.

1. The substantial question of law involved, formulated and to be answered in this tax appeal preferred under Section 260A of the Income Tax Act, 1961 (for short, ‘the IT Act’) states as under: -

“Whether the ITAT is justified in reversing the order of CIT(Exemption) holding that the assessee is entitled for registration under Section 12AA of the Income Tax Act by recording a finding perverse to the record?”

2. The aforesaid substantial question of law has to be answered in the following factual backdrop: -

3. On 29-12-1978, the respondent assessee Trust namely, “Shri Agrasen Jan Kalyan Trust” was registered under the Public Trust Act by the Sub-Divisional Officer, Kharsia. It was formed by prominent philanthropic spirited citizens, Late Shri Lakhiram Agrawal and Shri Niranjan Agrawal, with charitable objects including renovation of public properties, promotion of libraries, relief to poor, education, aid to widows/orphans, and supply of drinking water without caste or creed discrimination. The assessee Trust filed an application in Form No.10A before the Commissioner of Income Tax (Exemption), Raipur seeking registration under Section 12AA of the IT Act on