2021 (9) TMI 3

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.... PER RAJPAL YADAV, VICE-PRESIDENT: This is assessee's appeal against the order of the ld.CIT(Exemptions), Ahmedabad dated 23.8.2018 passed under section 12AA of the Income Tax Act, 1961. 2. In this appeal, only grievance of the assessee-trust is that the ld.CIT(Exemptions) is erred in rejecting application of the assessee for grant of registration under section 12AA for the reason of non-sub....

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....(E) rejected the application of the assessee-trust for grant of registration under section 12AA of the Income Tax Act, 1961. Aggrieved by the action of the ld.CIT(E), the assessee is now before the Tribunal. 4. Before us, the assessee has filed paper book containing pages from 1-59 which also contained copy of reply filed by the assessee before the ITO(HQ) dated 20.8.2018 along with enclosures ....

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....rival submissions and gone through the record carefully. As we noted herein, assessee is stated to be engaged in educational activities. It has registered with Charity Commissioner. We find that ld.CIT(Exemption) has rejected application of the assessee for grant of registration in the absence of details, which he sought from the assessee for adjudication. Before us, the assessee has filed a paper....

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....tion of the application for grant of registration without considering the same on merit and material placed on record, would burden assessee with a huge tax liability. We are of the view, if punishment in the shape of tax liability is weighed with negligence on the part of the assessee, then, the punishment of rejection of application by the ld.CIT is disproportionate to the negligence. Thus, we a....