TaxTMI 
TaxTMI 
2025 (6) TMI 2039
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....as well as the application u/s 80G of the Act. Aggrieved by the order the assessee is in appeal before the tribunal. 2. The assessee has raised following grounds of appeal : ITA No.3337/Del/2024 1. That having regard to the facts and circumstances of the case, Ld. CIT(E) has erred in law and on facts in rejecting the registration as well as provisional registration u/s. 12A(1)(ac)(iii) and 12A(1)(a)(vi) respectively vide order dated 30.05.2024 and that too without appreciating the facts and circumstances of the case and in violation of principles of natural justice and by recording the incorrect facts and findings. 2. That in any view of the matter and in any case, action of the Ld. CIT(E) in rejecting the registration as well as provisional registration u/s.12A(1)(ac)(iii) and 12A(1)(a)(vi) respectively vide order dated 30.05.2024, is bad in law and against the facts and circumstances of the case and is contrary to the principles of natural justice as the impugned order has been passed without granting adequate opportunity of hearing and by recording incorrect facts and findings. 3. That the appellant craves the leave to add, modify, amend or delet....
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.... that the assessee is a charitable trust and the activities carried on by the assessee are genuine. The queries raised and details required by the Ld. CIT(E) were all subject matter of verification by the Assessing Officer while completing the assessment. Therefore, since the genuineness of the objects of the trust and the activities of the trust were not in doubted by the Ld. CIT(E) he should not have rejected the registration u/s 12A as well as 80G of the Act on the ground that certain details were not furnished by the assessee which otherwise all the details were in fact furnished by the assessee. Thus, we direct the Ld. CIT(E) to restore the provisional registration granted to the assessee u/s.12A and also direct to grant registration u/s.12A as well as 80G to the assessee trust". 4. The Ld. Counsel for the assessee further submitted the detailed submission as under: Before Hon'ble Income Tax Appellate Tribunal, New Delhi In the case of Medical Service Society against order u/s 12AB(1)(b)(ii) Brief Synopsis The present appeal is against the order of Ld. CIT(E) u/s 12AB(1)(b)(ii) rejecting the application in Form 10AB for grant of registration u/s 12A(1)....
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.... * PB 134-228 is the copy of Activity Reports of charitable activities undertaken during FY 2020-21 to 2022-23, wherein PB 134-140 shows the Activities including Blood Donation Camps, Meetings, Doctors Symposium, Medical camps, Covid Health Centre etc. done by assessce and PB 141-228 are bills, vouchers, details and evidences of the expenses (including Flight tickets and Train tickets) incurred by assessee. PB 231, 232 are further replies filed to Ld. CIT(E) in impugned proceedings interalia submitting following: * PB 235-237, 242, 250, 265 are activity report from 1.4.2023 to 30.09.2023 showing free medical camps for flood victims, etc. together with bills and vouchers in respect of expenses. * PB 267 is the copy of Justification for application filed in Form 10AB for registration u/s 12AB and u/s 80G, showing charitable activities such as Community service and Impactful initiatives, Transparency and Accountability, Crisis Response and Relief work, Public Health Initiatives and Professional Collaboration and Development. * PB 268-269 is the copy of Justification of activities as per Objects of organization which shows the Main Aim and Objectiv....
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....s: 1. That the donations were given in this case by donors whose addresses are incomplete i.e. so not have House Number. In this regard, it is respectfully submitted that PB 89-102 is the details of donors filed to Ld. CIT(E) showing Name and Addresses of donors, Date of Donation, Amount, Mode of Donation and nature of donation during the three years up to 31.03.2023 and the observation of Ld. CIT(E) to allege that addresses are incomplete is without any basis, material or evidence and wrong on the face of it and deserves to be ignored. 2. Addresses of Beneficiaries of Medical Benefit have not been given. In this regard, it is respectfully submitted that PB 279-315 detail of beneficiaries of medical camps showing Name, Age, Gender, Aadhaar Number, contact details, Place of beneficiaries who attended the Free Medical Camp during the period April 2020 to Dec 2023 which shows the genuineness of the activities of the assessee and this observation of Ld. CIT(E) is neither here nor there and deserves to be ignored. 3. Travelling Expenses have not been corroborated with the objects of society. In this regard, it is respectfully submitt....
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....as received mostly donation in cash from donors claimed to be of kerala. The address of donors are incomplete, i.e. does not have House Number. 1. The assessee has not submitted narration of credit/debit entry above 10,000/- in the bank account as required vide letter dated 17.01.2024 for verification of amount received and paid by the assessee. 2. It is noted that an amount of Rs. 16.79 lacs has been claimed on account of low cost House in FY 2023-24 and Rs. 29.93 lacs in FY 2022-23 and Rs. 5.54 lacs in FY 2021-22. The assessee was required vide letter dated 06.02.2024 to file details of beneficiaries alongwith confirmation of low cost house. The details of beneficiaries have been filed, but confirmations from the beneficiaries have not been filed, 3. The assessee was asked to furnish the details of contractors, who were engaged in construction of low cost house project and drinking water project vide notice dated 06.02.2024. It is noted that the assessee has submitted copy of agreement of contractors, which are on simply on plain paper, which have no legal sanctity. 4. The assessee has failed to file confirmations from the donors exceeding Rs. ....