2025 (3) TMI 1077

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....t, 1961 holding that assessee has failed to satisfy about the genuineness of the activities. 2. Grounds of appeal raised by the assessee are as under: 1.) The grounds of appeal mentioned hereunder are without prejudice to one another. 2.) That the learned Commissioner of Income Tax (Exemption), Ahmedabad has erred in law and on facts in refusing to grant registration u/s 12AB of the Income Tax Act, 1961. 3.) Your Honour's appellant craves leave to add, to amend, alter, or withdraw any or more grounds of appeal on or before the hearing. 3. There is delay in filing of appeal by 234 days, the Ld. AR submitted that delay is caused due to the assessee is a senior citizen and have 68 years of age and less educated....

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....anager of Dawoodi Bohra Jamat has apply for registration of the trust u/s. 12AB of the I.T. Act, 1961 was filed electronically and as per data available in ITBA, the same is filed on 24/11/2022 by the assessee in Form No. 10AB under Rule 17A of the I.T. Rules, 1962. The Rule 17A(1) of the Income Tax Rules prescribes the different forms to be filed and the detail of Form filed are under; Sr. No. Particulars Form No. Date 1. Application for registration 10A 03.02.2022 2. Provisional Registration Form AY 2022-23 to AY 2024-25 10AC 10.02.2022 3. Application for permanent registration 10AB 24.11.2022 4. Rejection of Permanent registration 10AD 20.05.2023 7. A notice was issued by the....

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....titution/deed with the activities could be carried out. Thus, the genuineness of the activities does not get established, due to non compliance by the assessee. Section 12AB makes, it very clear that before granting registration under this section, the Commissioner has to satisfy himself about the genuineness of the activities of the trust or institution and also he has to verify that these activities are in consonance with the objects of the trust or institution. Further, he has to ensure that other laws material for the purpose of achieving objects are complied with. The assessee has again not furnished any detail The Ld. CIT(E) has rejected the application for registration with further observation: "From the above discussions, i....