12AA registration rejection remanded for fresh factual inquiry; consequential 80G approval also sent back for reconsideration.

Rejection of registration under section 12AA was set aside because the Commissioner of Income-tax (Exemptions) had not sufficiently examined the society's objects, aims and supporting material. The matter required a proper factual inquiry after giving the assessee full opportunity to produce evidence and be heard. As the approval under section 80G was consequential to the registration issue, that request was also remitted for fresh consideration. The dispute was not fit for final determination on the existing record and had to be decided afresh on merits.

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Issues: Whether the rejection of registration under section 12AA and the consequential refusal of approval under section 80G required fresh consideration by the Commissioner of Income-tax (Exemptions).

Analysis: The assessee had sought registration and exemption for a society claiming educational and public benefit objects. The material on record before the Commissioner was found to be insufficiently examined, and the rejection order did not adequately address the assessee's aims, objects, and supporting evidence. In these circumstances, the dispute was not fit for final adjudication on merits and required a proper factual inquiry after giving the assessee full opportunity to produce evidence and be heard.

Conclusion: The rejection was set aside for fresh decision by the Commissioner of Income-tax (Exemptions). The application for registration under section 12AA was remitted for reconsideration, and the request under section 80G, being consequential, was also remitted.

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