2025 (4) TMI 324

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....:- 1. The CIT(E) erred in law and on facts in passing the impugned order u/s. 10AD cancelling the registration vide the impugned order dated 11.9.2024 and not granting permanent registration u/s. 12AB of the Act particularly (i) when the provisions registration granted to the Trust u/s. 12AB of the Act on 11.12.2023 was valid from AY 2024-25 to 2026-27 because the Trust was new, constitute duly on 12.4.2022; (ii) there is no allegation of any mis- representation of the activities as per the Trust Deed on record of the Revenue; and (iii) the charitable activities were yet to be commenced being initial stage where not only funds were being collected from the members being made and fund were being collected from members / donors to ca....

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....ision registration granted to the Trust u/s. 80G of the Act on 11.12.2023 was valid from AY 2024-25 to 2026-27 because the Trust was new, constituted only on 12.4.2022; (ii) there is no allegation of any mis-representation of the activities as per the Trust deed on record of the Revenue; and (iii) the charitable activities were yet to be commenced being initial stage where not only funds were being collected from the members being made and funds were being collected from members /donors to carry out the objects of the Trust. 3. The first accounting year of the trust ended on 31.3.2023 as per the balance sheet and bank statement filed on the web portal clearly indicated that the funds collection drive commenced in the subsequent yea....

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....e for grant of registration was fixed for compliance and issued questionnaire seeking certain details, from the assessee, but the assessee failed to comply with the same, hence, the Ld. CIT(E) rejected the application for grant of registration u/s. 12A(1)(ac)(vi)-B of the Act. He further noted that since application in Form 10AB for registration u/s, 12A(1)(ac)(vi)-B was rejected due to part submission of the details/ information to verify the genuineness of the activities, charitable objects and commencement of the activities charitable, hence, approval u/s. 80G(5)(iv)-B was also rejected. Against the aforesaid actions of the Ld. CIT(Exemption), Delhi assessee is in appeals before us. 5. We have heard both the parties and perused the re....