2024 (9) TMI 910

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....inst the order of the learned Commissioner of Income Tax (Exemption) [CIT(E)], Pune dated 29.03.2023 wherein the application filed by the assessee in Form No. 10AB under Clause (iii) of Section 12A(1)(ac) of the Income Tax Act, 1961 (the Act) on 29.02.2022 was rejected and the provisional registration granted on 28.05.2021 was also cancelled. 3. The assessee has raised the solitary ground that submission dated 06.02.2023 and further refusing to rectify the error as per application dated 14.02.2024 has resulted into rejection of registration u/s. 12AB wrongly. 4. The assessee has stated that the appeal filed by the assessee is late by 308 days. The assessee explained that the order of the rejection was passed on 29.03.2023 without cons....

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....on of error only on 14.02.2024, therefore, in fact there is no justification or sufficient cause from 29.04.2023 till 14.02.2024. However, we find that by filing the application late the assessee has not got any benefit. In fact, if the assessee is not diligent about the limitation of time in pursuing his cause, he does not gain any advantage but he is at more disadvantage that he may lose as good case for bad reasons. However, looking to the peculiar facts of the case, where the claim of the assessee is that it has submitted certain details on 06.02.2023 which was not considered by the learned CIT(E) when the order of rejection was passed on 29.03.2023, it causes severe prejudice to the assessee. Even despite the making an application for ....