Duplicate Form 10AB registration filing despite valid approval for AY 2024-25; ex parte rejection set aside, registration continues.

The dominant issue was whether the CIT(E) could reject ex parte a fresh Form 10AB application under s. 12A(1)(ac)(vi) when the assessee already held a valid registration/approval covering AY 2024-25. The ITAT held that, once an existing valid registration for the relevant assessment year is undisputed, rejection of an inadvertent duplicate application is unsustainable in principle and cannot prejudice continuation of the earlier grant. The CIT(E) was directed to verify the existence of valid registrations for AY 2024-25 and, upon verification, permit the registration to continue for that year in terms of the original grant; the appeals were allowed for statistical purposes.

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1. ISSUES PRESENTED AND CONSIDERED

(i) Whether rejection of the assessee's applications filed in Form 10AB for AY 2024-25 under section 12A(1)(ac)(vi) and under section 80G could be sustained when the assessee already had valid registration/approval covering AY 2024-25 and the Form 10AB filings were stated to be inadvertent.

(ii) What consequential direction was required to preserve/continue the assessee's existing registration/approval for AY 2024-25, including verification of the existence of valid registrations/approvals for that year.

2. ISSUE-WISE DETAILED ANALYSIS

Issue (i): Sustainability of rejection of Form 10AB applications for AY 2024-25 despite existing validity for the same year

Legal framework: The Tribunal dealt with the applications and rejection orders in relation to section 12A(1)(ac)(vi) and section 80G, in the context of filings in Form 10AB and consequential rejection orders in Form 10AD, as reflected in the impugned orders.

Interpretation and reasoning: The Court found the material facts to be clear: (a) the assessee had a valid registration/approval for AY 2024-25 in both matters; and (b) a fresh Form 10AB for AY 2024-25 was filed inadvertently and thereafter rejected ex parte. On these findings, the Court held that once a valid registration/approval already existed for AY 2024-25, rejection of a fresh, inadvertent application for that same year could not be sustained "in principle", because it had the effect of denying a benefit for a year already covered by existing validity.

Conclusion: The rejection orders could not be sustained in principle in view of the existing valid registration/approval for AY 2024-25, and relief was warranted on that basis.

Issue (ii): Appropriate operative relief and verification direction for continuation of existing registration/approval for AY 2024-25

Legal framework: The Tribunal confined its operative directions to the manner in which effect should be given to its appellate order by the authority who passed the impugned orders.

Interpretation and reasoning: While holding that the rejection could not stand in principle, the Court directed that, at the stage of giving effect, the authority must verify the existence of valid registrations/approvals for AY 2024-25 in both matters. Upon such verification, the authority was directed to allow the registration/approval to continue for AY 2024-25 as per the original order granting such registration/approval.

Conclusion: The Court ordered verification of existing validity for AY 2024-25 and continuation of registration/approval for AY 2024-25 in accordance with the original grant; the appeals were allowed for statistical purposes.

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