2024 (7) TMI 492

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....ar 2019-20. 2. The assessee has taken the following grounds of appeal:- "1.  That the Ld. CIT(Exemption), Ahmedabad has erred in law and on Facts while rejected the registration application U/s 12AA of the Income Tax Act, 1961 and therefore the order passed by CIT(Exemption), Ahmedabad may please be deleted. 2. That the assessee has made application u/s 12AA of the I.T. Act, 1961. However, the same was rejected without giving proper opportunity of being heard and without considering the reply filed by the assessee on 19/09/2019 is against the provision of law and therefore the order passed on 19/09/2019 for rejection of application u/s 12AA dated 19/09/2019 may please be quashed. 3. That the objects of the assessee trust are eli....

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.....10.2019 and on the very same set of facts, the assessee trust was granted the registration certificate on 20.03.2020. It was submitted that on receiving the registration certificate, the assessee trust was under the genuine belief that the exemption certificate is applicable for the impugned Assessment Year 2019-20 as well, since CIT (Exemptions) had incorrectly rejected the first application for registration on the very same set of facts, on which set of facts, the later certificate of registration under Section 12AA of the Act was granted. It was submitted before us that the assessee trust was never advised by the consultants to file an appeal against the order of rejection of certificate of registration under Section 12AA of the Act dat....

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....e incorrect impression that once registration had been granted under Section 12AA of the Act, upon filing of the second application on the same set of facts, the benefit of exemption was available to the assessee trust for the impugned assessment year as well and secondly, it was submitted that the assessee has been genuinely carrying out charitable activities, which is evident from the fact that on filing of second application for grant of registration, the CIT(Exemptions) had granted registration under Section 12AA of the Act to the assessee trust on the same set of facts. Accordingly, it was submitted that looking into the instant facts, the delay in filing of the present appeal may kindly be condoned. Further, the counsel for the assess....