2025 (7) TMI 32

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...."1. Your appellant submits that the CIT (E) has erred in rejecting the, application for registration under section 80G ignoring the submission made. The rejection is bad in law. 2. Your appellant submits that the CIT(E) has erred in holding that there is no substantial charitable activity being carried out by ignoring the submission made in response to the notices issued. 3. Your appellant submits the CIT (E) having granted the registration under section 12AB ought not to have rejected the registration under section 80G(5) is bad in law. 4. Your appellant submits that the CIT(E ) ought to have provided another hearing having submitted the opportunity of information asked for nature activities taken up by till date....

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....as pleaded that the learned CIT (E) may be directed to grant the registration/approval u/s 80G(5) of the Act to the assessee. 5. On the other hand, the learned DR has submitted that the registration granted u/s 12AB would not ipso fact entitle the assessee to get the approval u/s 80G(5) until and unless the competent authority satisfied that the assessee has actually carried out the charitable activities as required u/s 80G of the Act. He has relied upon the impugned order of the learned CIT (E). 9. We have considered the rival contentions as well as the relevant material available on record. The learned CIT (Exemption) has rejected the application of the assessee by recording the reasons in para 3 of the impugned order as under: ....