2025 (6) TMI 630

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....has raised the following grounds of appeal :- "1. Ground 1: Violation of principle of natural justice 1.1 In the facts and circumstances of the case and in law, the learned CIT (Exemption) erred in rejecting the application for final registration under section 12A of the Act without affording the Appellant adequate opportunity to present its case. 2. Ground 2: Challenging rejection of registration under section 12AB 2.1 In the facts and circumstances of the case and in law, the learned CIT(Exemption) erred in rejecting the application for final registration under section 12AB of the Act without appreciating that the alleged reasons for rejection were adequately addressed in the submissions forming part of....

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....e Ld. CIT(E) issued notice on 10.05.2024 through ITBA portal which was duly served on the assessee requesting the assessee to upload certain information/clarification such as date of commencement of activity, date of expiry of provisional registration, details of any other law applicable for achievement of objectives and the proof of compliance of said law, proof of identity of main trustees / managing trustees / directors / trustees / secretary, list of donors, note on activities carried out in the last three years/inception etc. under the provisions of section 12AB(1)(b)(i) of the Act. The compliance was sought by 27.05.2024. On verification of the details/documents filed by the assessee, the Ld. CIT(E) noticed various discrepancies which....

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....er rejecting the application of the assessee and cancelling the provisional registration granted earlier to the assessee on 31.08.2021 u/s 12AB r.w.s. 12A(1)(ac)(vi) of the Act by observing as under : 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 th....