2025 (7) TMI 742

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.... as "the Act") dated 20.12.2024. 1.1. The Registry has informed that the appeal filed by the assessee is barred by limitation by 13 days. An affidavit along with an application seeking condonation of delay has been filed by the assessee. The contents of the condonation petition are as under: "Sri Maheswari Dharmasala Trust is in existence since 11th February 1991. Certification u/s 12A order issued on 2nd April 1991 and 80G order issued on 30th July 1992 for the perpetuity. A copy of the Order(s) is attached. Due to the amendment in the Income Tax Act, 1961 pertaining to charitable Trust effective from 1st April 2020, Assessee filed form 10A pertaining to 80G(5) on 31 August 2021. However, Assessee didn't file form 10A pertaining to ....

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....the delay which was purely unintentional, and for this act of kindness, we shall remain much grateful." 1.2. Considering the application for condonation of delay and the reasons stated therein, we are satisfied that the assessee had a reasonable and sufficient cause and was prevented from filing the instant appeal within the statutory time limit. We, therefore, condone the delay and admit the appeal for adjudication. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. That the rejection of form 10AB is arbitrary and not justified as Assessee had filed form 10AB for Sec 12A within the extended due date of 30th June 2024 vide circular no. 07/2024 dated 25.04.2024. Mere non-filing of form 10A (to g....

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....tration u/s.12A(1)(ac)(iii) of the Act in Form No. 10AB. Accordingly, notice was issued to the assessee calling for certain information. In reply, the assessee submitted various details along with the supporting documents. The Ld. CIT(Exemption) perused the documents filed by the assessee and issued another notice seeking certain clarifications from the assessee. Since no reply from the assessee was received, the Ld. CIT(Exemption) rejected the assessee's application u/s.12A(1)(ac)(iii) of the Act and further cancelled the provisional certificate issued to the assessee observing as under: "The assessee has failed to submit/furnish submit/furnish its reply on the above mentioned query and accordingly the genuineness of the activities of th....