2025 (6) TMI 703

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....t, ARs. For The Respondent : Dr. Darsi Suman Ratnam, CIT. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: These two appeals are filed by the assessee against the order of the Commissioner of Income Tax (Exemption), Ahmedabad, (in short 'the CIT(E)'), dated 18.10.2024 & 21.10.2024 in respect of rejection of registration under Section 12A of the Income Tax Act, 1961 (in short 'the Act') and rejec....

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....he Ld. CIT(A) had passed the impugned order rejecting the application for registration u/s.12A of the Act and the provisional registration granted earlier was also cancelled. Further, in the absence of registration u/s.12A of the Act, which is a pre-requisite for grant of approval u/s. 80G of the Act, the application for approval u/s 80G(5) was also rejected. 3. Shri Jigar Shah, Ld. AR of the ass....

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..... 4. Per contra, Ld. CIT.DR had no objection if the matter was set aside to the file of the Ld. CIT(E). 5. We have considered the submission of the assessee. It is found that only one opportunity was allowed by the Ld. CIT(E) vide show cause notice dated 01.10.2024 to explain the nature of objects of the trust, which was held to be non-charitable by the Ld. CIT(E). It is also found that the Ld. ....