Tribunal grants final chance for charity registration & approval under Income Tax Act

The Tribunal directed the CIT(E) to grant the assessee a final opportunity to substantiate charitable activities for registration u/s. 12AA. The issue of approval u/s. 80G was remanded for fresh adjudication by the CIT(E). The appeals by the assessee were allowed for statistical purposes, highlighting the significance of proving charitable activities for registration and approval under the Income Tax Act.

---

---

Issues involved:
- Denial of registration u/s. 12AA and approval u/s. 80G by CIT (Exemption), New Delhi.

Analysis:
- The assessee, a society, applied for registration u/s.12AA and exemption u/s.80G.
- The CIT(E) requested documents to support the claim, but the assessee provided only partial details.
- Several notices were issued to the assessee to submit required details, including financial statements, list of donors, and evidence of charitable activities.
- The CIT(E) noted discrepancies in the financials, questioning the genuineness of activities and expenses.
- The CIT(E) held that the assessee failed to establish the charitable nature of its activities, leading to the rejection of registration u/s. 12A/12AA and subsequently denial of approval u/s. 80G.
- The assessee appealed to the Tribunal, arguing denial of reasonable opportunity to be heard, and challenging adverse inferences drawn by the CIT(E).
- The Tribunal directed the CIT(E) to grant one final opportunity to the assessee to substantiate charitable activities for registration u/s. 12AA.
- The issue of approval u/s. 80G was also remanded for fresh adjudication by the CIT(E).
- Both appeals by the assessee were allowed for statistical purposes, emphasizing the importance of substantiating charitable activities for registration and approval under the Income Tax Act.

---