2022 (3) TMI 879

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.... Sri.Pradeep Kumar, CIT-DR ORDER PER GEORGE GEORGE K, JM : This appeal at the instance of the assessee is directed against CIT(Exemption)'s order dated 24.03.2021. 2. There is a delay of 176 days in filing this appeal. The assessee has filed a petition for condonation of delay and an affidavit stating therein the reasons for belated filing of this appeal. On perusal of the reasons stat....

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....ineness of the activities of the assessee-trust. 4. Aggrieved by the order of the CIT(E), the assessee has filed this appeal before the Tribunal. The learned AR has filed two sets of paper book, in total comprising of 45 pages, inter alia, enclosing therein notice for registration u/s 12AA, reply to the notice for registration u/s 12AA of the I.T.Act, order granting registration u/s 12AA of the....

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.... this context, it is relevant to note that the very same Officer who refused to grant approval u/s 80G of the Act, was the Officer, who granted registration u/s 12AA of the Act a day prior, i.e., on 23.03.2021. Copy of the order u/s 12AA of the I.T.Act is placed on record at page 3 of the paper book filed by the assessee. We fail to understand how registration u/s 12AA of the I.T.Act has been gran....