2025 (4) TMI 652

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....d of by this common order. 2. In ITA No.2715/PUN/2024 the assessee has challenged the order of the CIT(Exemption) in rejecting the application for registration u/s 12A of the Act while ITA No.2716/PUN/2024 relates to the order of the CIT(Exemption) in denying the approval u/s 80G of the Act. 3. Facts of the case in brief, are that the assessee filed an application in Form No.10AB on 24.05.2024 for registration of the trust under clause (iii) of section 12A(1)(ac) of the Act. With a view to verify the genuineness of the activities of the assessee and compliance to requirements of any other law for the time being in force by the trust / institution as are material for the purpose of achieving its objects, a notice was issued through ITBA po....

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....as nothing to say in the matter. 7. Considering the above facts discussed in the show notice and discrepancies noticed and also that the assessee has not complied with the provisions of section 12AB(1)(b)(i) of the Income Tax Act, 1961 as well as the provisions of Rule 17A(2) of Income Tax Rules, 1962 in spite giving sufficient opportunities, the undersigned is unable to draw any satisfactory conclusion about the genuineness of activities of the assessee and compliance of requirements of any other law for the time being in force by the assessee as are material for the purpose of achieving its objects. 8. In view of the above, the application filed by the assessee is hereby rejected and the provisional-registration-granted on 20/02/202....

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....hich he has asked for certain details on account of certain discrepancies found from the submissions made by the assessee earlier for which he rejected the application filed by the assessee for grant of registration u/s 12A of the Act and also cancelled the provisional registration granted earlier u/s 12AB. Since the application for grant of registration u/s 12A of the Act was rejected and the provisional registration granted earlier was cancelled, he rejected the application for approval u/s 80G of the Act. It is the submission of the Ld. Counsel for the assessee that due to the mistake on the part of the employee of the trust in not communicating the notice, the assessee could not respond to the second notice. It is also his submission th....