2025 (6) TMI 638

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....iii) of the Income Tax Act, 1961 ('Act' for short) and consequently also denied the exemption under Section 80G of the Act. 2. Brief facts of the case are that, the Appellant filed an application for registration u/s 12A (1)(ac)(iii) of the Act. The Assessee claimed to be a charitable entity incorporated on 09/10/2020 under Section 8 of Companies Act, 2013. The appellant has not furnished application for seeking registration u/s 12A (1)(ac) (vi) of the Act at the time of incorporation and not claimed exemption up to the Assessment Year 2022-23. On 21/05/2022, the appellant applied for registration u/s 12A (1)(ac) (vi) of the Act by filing application in Form No. 10A. The appellant was granted with a provisional registration for t....

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....rchased the land, however, the purpose for which the land was purchased is still not clear as the appellant emphasizing over the use of land on any objects of the appellant. Appellant has not specifically mentioned the reason for purchase of the land, further submitted that the appellant has also invested huge amount for preparing portable cabins thereon and not disclosed the activities to be conducted thereon. Thus, the reason for purchase of the land is not clear. Further, the Ld. Ld. Departmental Representative relying on the various reasons assigned by the Ld. CIT(E) for rejecting the applications sought for dismissal of the Appeal. 6. We have heard both the parties and perused the material available on record. The Ld. CIT(E) while r....

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.... during Financial Year 2021-22. 10. It is the specific case of the Appellant that, the Appellant was unable to obtain documentary evidences with respect to the charitable expenses incurred during the FY.2021-22, when the proceedings before Ld. CIT(E) was under progress, the Appellant in its submission, expressed its inability to produce the details relating to medical relief, protection of environment and other general public expenses and sought for further time to provide the details. Apart from the same, as observed earlier, the Appellant has not claimed exemption u/s. 11 of the Act for A.Y.2022-23 (F.Y.2021-22) and the application seeking permanent registration was filed for A.Y.2026-27 onwards. In the above peculiar circumstances, no....

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....s. 42,116/- and the Assessee has reimbursed the same. It is pertinent to note that the Ld. CIT(E) has not brought any material to show that the expenses reimbursed by the Assessee aggregating to Rs. 42,116/- are not genuine expenses. In any case, there is no illegality in the transactions of receipt of donations from and reimbursement of expenses to the related concerns. Hence, there was no credible reason available with Ld. CIT(E) to doubt those transactions so as to deny permanent registration u/s. 12AB of the Act. 14. The Ld. CIT(E) has stated that the Assessee has received donations out of CSR funds of donor companies, further observed that the donations given by a trust named DREAM is against its objects. 15. It is seen that the ....