2025 (7) TMI 251

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....for registration of u/s 12AB of the Income Tax Act, 1961. 2. Let us take up the appeal of the assessee in ITA No. 2153/Del/2025. 3. The only issue to be decided in this appeal is as to whether the ld CIT(E) was justified in denying the registration u/s 12AB of the Act to the assessee. 4. We have heard the rival submissions and perused the materials available on record. The assessee trust was started on 31.05.2022. The assessee obtained registration u/s 12A(1)(ac)(vi) of the Act on 12.08.2022. The assessee filed an application on 20.09.2024 in Form 10AB for regular registration u/s 12A(1)(ac)(iii) of the Act. The main objects of the assessee as per the Form 10AB of the Act as noted by the ld CIT(E) are for imparting education and ad....

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....in how the agreement has been entered into with M/s. Edujobs Academy Pvrt. Ltd even before the parent agreement with NSDC. The assessee submitted that though the formal agreement had been executed on 24.09.2024, the agreement with NSDC is applicable from 01.04.2024 to 31.03.2009. The work had already started and discussion had already been taking place with NSDC to start the services on ground. The agreement with M/s. Edujobs Academy Pvt. Ltd executed on 11.09.2024 was in anticipation of the formalization of the NSDC agreement as it was already in pipeline and discussions were going on. This was necessary to ensure operational readiness and alignment with the broader objectives of the scheme. 5. The ld CIT(E) however did not agree with t....

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....nd 31.03.2024 by the trust. The provisional balance sheet of the assessee trust as on 31.12.2024 was placed on record which are enclosed in pages 101 to 103 of the Paper Book, wherein it can be seen that a sum of Rs. 56,73,335/- has been spent on activities carried out by it. The assessee submitted the complete details together with the bills, vouchers and photographs in respect of activities carried out by it. The details of training sessions conducted at the Skill India Training Centre at various locations together with the respective candidates undergoing training of the assessee trust were filed. The bills and vouchers raised by M/s. Edujobs Academy Pvt. Ltd in relation to the training activity carried out were enclosed on sample basis ....