2025 (4) TMI 981

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....facts and issues, for the sake of convenience, they are disposed of by this common order. 2. The Commissioner of Income Tax (Exemption), Ahmedabad [hereinafter referred to as "CIT(E)"] rejected the application for registration under Section 12A(1)(ac)(iii) of the Act vide order dated 23/10/2024 on the grounds that the assessee failed to submit audited annual accounts for Financial Years (FYs) 2021-22, 2022-23, and 2023-24 despite multiple notices. The CIT(E) held that due to non-submission of these crucial documents, the genuineness of the trust's activities could not be verified, leading to rejection. Simultaneously, the CIT(E) rejected the application under Section 80G(5) of the Act on the same date, 23/10/2024, citing that the tru....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....unds either before or in the course of hearing of the appeal Facts of the Case: 3. The assessee Trust granted provisional registration under Section 12A(1)(ac)(vi) of the Act on 08/02/2022. Subsequently, the assessee filed an application for final registration in Form 10AB on 27/04/2024. Additionally, an application for approval under Section 80G(5) of the Act was filed. 4. The CIT(E) issued notices on 02/07/2024 and 12/08/2024 seeking submission of details, including financial statements. The assessee partially complied with the notices but failed to submit audited annual accounts for FYs 2021-22, 2022-23, and 2023-24. A final notice dated 15/10/2024 was issued, reiterating the requirement to submit audited financials and other de....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ppeal, he misunderstood the process and initially attempted to challenge the rejection through an incorrect approach, leading to misdirected efforts. Once the trustees became aware of the error, they promptly engaged a Chartered Accountant (CA), who immediately filed the appeal. However, by that time, the appeal was delayed by 8 days. 5.2. The delay, therefore, was not intentional or due to negligence, but arose due to lack of expertise and administrative mismanagement, which has since been rectified by appointing professional assistance. 6. We have carefully considered the rival submissions and the material on record. It is evident that the rejection of the application under Section 12A of the Act was based on non-submission of audit....