2025 (5) TMI 745

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.... 1. That the order dated 25/12/2024 is against the law and material available on record. 2. The Ld. CIT has erred on facts and in law in rejecting the application filed by the assessee u/s 80G(5) First Proviso clause (iii) in form No. 10AB seeking registration u/s 80G of IT Act on the ground that assessee is not registered under Rajasthan Public Trust Act, 1959. 3. The Ld. CIT has erred on facts and in law in rejecting the application filed by the assessee by stating that genuineness of activities is not proved. It is respectfully submitted that assessee has furnished all the required details alongwith details of bank transactions, bills, vouchers etc and established the genuineness of activities. Therefore, the order pas....

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....details bank statements, cash book/bank book alongwith bank transaction more than Rs. 10,000/- in order to verify the nature of debit and credit entries. Thus, the nature of entries in bank account is unverified and activities do not seem genuine. Hence from the above it is clear that the activities are not verifiable and it could not be determined whether the applicant is genuinely carrying out charitable activity and it's cannot be ascertained that activities are as per objects. Therefore, the applicant claim of registration u/s 80G considered as to be rejected on ground of not proving its genuineness of activity and thereby the application for registration u/s 80G was rejected on the following grounds: - *. Non registrati....

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.... and 80G was rejected on the grounds that the activities of the trust is not genuine. Since 12A application has been approved registering, the assessee as chargeable trust after considering the genuineness of the activity. This decision of ld. CIT(E) requires reconsideration. He submitted in support of copy of 12A registration certificate issued on 24.09.2021. As regards the non-registration under the RPT Act, the assessee submitted that they have filed an application before the competent authority on 29.06.2024 for registration of the assessee trust under the RPT Act and this observation being curable he prayed to grant one more chance to contest the issue on merits. 6. Per contra, the ld. DR relied upon the order of ld. CIT(E) but at t....