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ITAT allowed the appeal against rejection of registration under section 12AB. The assessee trust filed Form 10AB within the extended deadline of 30.06.2024 but incorrectly cited item (B) of sub-clause (vi) instead of section 12A(1)(ac)(iii). The rejection was based solely on this procedural error. ITAT held that CBDT Circular No. 7/2024 provides remedial framework for such inadvertent non-compliance in evolving regulatory environment. The trust's charitable activities were never questioned, and it previously held provisional registration. Applying substance over form doctrine, ITAT ruled that procedural lapses should not defeat substantive entitlements of bona fide charitable trusts. The rejection order was set aside and matter remanded to CIT(Exemption) for fresh consideration, emphasizing that technical defects cannot override genuine compliance intentions.
ITAT allowed the appeal against rejection of registration under section 12AB. The assessee trust filed Form 10AB within the extended deadline of 30.06.2024 but incorrectly cited item (B) of sub-clause (vi) instead of section 12A(1)(ac)(iii). The rejection was based solely on this procedural error. ITAT held that CBDT Circular No. 7/2024 provides remedial framework for such inadvertent non-compliance in evolving regulatory environment. The trust's charitable activities were never questioned, and it previously held provisional registration. Applying substance over form doctrine, ITAT ruled that procedural lapses should not defeat substantive entitlements of bona fide charitable trusts. The rejection order was set aside and matter remanded to CIT(Exemption) for fresh consideration, emphasizing that technical defects cannot override genuine compliance intentions.
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