2025 (7) TMI 760

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.... grounds have been taken in this appeal: - 1. The Ld. CIT (Exemption), Ahmedabad had erred in rejecting the application filed by the Appellant Trust on the ground that application filed in Form 10AB has not filed within time limit prescribed and therefore it is not maintainable. On facts and circumstances of the case, the action of the Ld. CIT (Exemption) of rejecting application filed u/s 12A(1)(ac)(vi-B) of the Act which is incorrect. The same be held now. 2. Without prejudice to the above, the appellant trust has selected the incorrect section code - item (B) of sub clause (vi) of clause (ac) of subsection (1) of section 12A instead of the correct code, which is sub clause (iii) of clause (ac) of sub-section (1) of sect....

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.... be allowed an opportunity to rectify the mistake in the application and the matter may be set aside to the file of Ld. CIT(E) with a direction to re-adjudicate the issue. 4. Per contra, Shri Alpesh Parmar, the ld. CIT-D.R. submitted that the Ld. CIT(E) had rightly rejected the application as filed by the assessee. 5. We have considered the submission of the assessee and perused the materials placed before us. The Ld. CIT(E) had rightly rejected the application filed by the assessee Trust u/s 12A(1)(ac)(vi) of the Act, as the conditions for such approval was not found satisfied. In fact, the Ld. CIT(E) had made certain queries in the course of the proceeding before him, which was responded by the assessee. However, the fact that there....