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2024 (11) TMI 223

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....Act) and Form No. 10AB under Clause (iii) of Section 12A(1)(ac) of the Act dated 29.09.2023 was rejected and provisional registration granted on 22.01.2022 u/s. 12AB was also cancelled. 02. The Assessee is aggrieved and has raised following numeral two grounds of appeal: - "1. On the facts of the case and in Law, the learned CIT [Exemption] Pune has erred in rejecting the application u/s 12A for approval of the Appellant Trust by holding that. i) Trust Deed copy submitted was not self- certified Rule 17A(2)(a) by the trustee, which is an inadvertent error. ii) Details of date & place of each activity were not furnished by the Trust but the CIT[E] overlooked the fact it is not possible to provide because public come and attend spiritu....

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....ed notice on 23.11.2023. He has asked for several details as per Paragraph-2 of that notice which is reproduced at Pages 3 to 7 of the order. The assessee filed part details on 08.01.2023. The learned CIT(E) was also requested to grant adjournment of hearing for further submission of the detail. Same was granted upto 18.12.2023 but the assessee did not respond and, therefore, one more notice was issued on 10.01.2024. The assessee did not reply to that notice and therefore, the learned CIT(E) perused already furnished details. He found several discrepancies. Based on this, the assessee was specifically informed that in the event of failure to comply by the due date the application would be rejected. The due date was 08.02.2024, the assessee ....

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....mit any information on seven points stated at Paragraph No.2.2 of his order, rejection of the application is proper. 06. We have carefully considered the rival contentions and have perused the orders of the learned CIT(E). We find that the assessee is a trust carried on charitable activities like arrangement of food for conducting pooja and relief to poverty. The activities are for the benefit of public at large. The assessee has also submitted the details on 12.01.2024 as per letter placed at Page No.68 of the paper book. There is no reference of the information submitted on that date in the order of the ld CIT (E) Thus, it is true that the learned CIT(E) has issued the show cause notice on 01.02.2024 but there is no reference of the deta....