2025 (6) TMI 974

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....see's application for registration under section 12AB of the Income-tax Act, 1961[hereinafter referred to as "the Act"] and cancelled the provisional registration earlier granted under section 12A(1)(ac)(iii) of the Act. Condonation of Delay 2. We find that the present appeal has been filed with a delay of 58 days, as against the limitation prescribed under section 253(3) of the Act. The assessee has filed an application supported by an affidavit sworn by Shri Abhaykumar Manubhai Fadia, trustee of the trust, explaining the reasons for such delay. As per the affidavit and submissions the impugned order of the CIT(Exemption) dated 03.09.2024 was sent via email to the registered email address of the assessee trust. However, the email acc....

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....essee was expected to furnish requisite documents and evidences as per Rule 17A(2) of the Income Tax Rules, 1962. The CIT(Exemption) issued notices dated 02.07.2024 and 05.08.2024 calling upon the assessee to furnish the necessary documents and information. However, there was no compliance from the assessee in response to these notices. In the absence of any material to verify the genuineness of the trust's activities, the CIT(Exemption) proceeded to reject the application for registration under section 12AB and simultaneously cancelled the provisional registration vide the impugned order dated 03.09.2024. The said order was communicated electronically to the registered email address of the assessee. 5. Aggrieved by the order of CIT(....

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....ns, the material placed on record, and the contents of the impugned order passed by the CIT(Exemption). From the record, it is evident that the assessee is a religious trust engaged in some religious / charitable activities and was granted provisional registration under the Act. In pursuance of statutory compliance, the assessee filed its application for regular registration in Form 10AB. Along with the application, the assessee submitted various documents including audited financial statements, trust deed, and other supporting materials relevant to its activities and objectives. Despite the availability of such documents, the impugned order proceeds to reject the application solely on the ground of non-compliance with notices issued under ....