2023 (7) TMI 797

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....f assessee-trust for registration under Section 12AB of the Income Tax Act, 1961 (in short, the Act). The assessee has raised following grounds of appeal: "(1) On the facts and circumstances and in law, the learned CIT(Exemption) was not justified in rejecting application u/s 12A, particularly when the appellant complied with all the details as also rendered evidence of activities undertaken in consonance with the objects. (2) The learned CIT(E) was driven by extraneous considerations while rejecting application. (3) The learned CIT(E) ought to have taken a judicial and liberal view rather than a hyper technical view. (4) The appellant craves leave to add, alter or vary any of the grounds of appeal." 2....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ing registration, he has to satisfy himself about genuineness of the activities of the trust and to verify that activities are in consonance with object of the trust or institution. Aggrieved by the order of ld. CIT(E), the assessee has filed present appeal before this Tribunal. 3. We have heard the submissions of learned Authorized Representative (ld. AR) of the assessee and the learned Commissioner of Income Tax- Departmental Representative (ld. CIT-DR) for the revenue. The ld. AR of the assessee submits that the assessee furnished complete details while filing/uploading required details at the time of filing of application. The ld. AR of the assessee submits that they have furnished copy of trust deed, registered under the provisions ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ion, the ld. AR of the assessee submits that the matter may be restored back to the file of ld. CIT(E) with direction to consider the application of assessee afresh and to pass he order in accordance with law. The ld AR for assessee submits that he is ready to make correction in the Form-10AB and at other places with the satisfaction of ld CIT(E). 5. On the other hand, the ld. CIT-DR for the revenue submits that there was a mismatch in various documents. The assessee has given different name in Form-10AB, which is not matching with the name mentioned in registration certificate as well as in trust deed. The ls CIT(A) while rejecting application due to mismatch of name in different evidences. The object and activities of the assessee was ....