2025 (9) TMI 25

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....d u/sec. 80G of the Income Tax Act, 1961 [in short "the Act"], relating to the assessment years 2022-2023 and 2025-2026, respectively. Since common issues are involved in both these appeals, these appeals were heard together and are being disposed of by this single consolidated order for the sake of convenience and brevity. 2. Briefly stated facts of the case are that, the assessee-trust viz., Jiddu Krishnamurti Centre was in existence since 13.10.1995 and is registered u/sec. 12A and 80G of the Income Tax Act, 1961 [in short "the Act"] prior to 01.04.2021. The appellant-trust got provisional registration issued by the CPC, Bengaluru on 05.04.2022 u/sec. 12A and 80G of the Act. The appellant-trust has e-filed application on 26.09.2024 in F....

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....learned CIT(E) rejected the application filed by the appellant-trust on technical grounds of filing incorrect application in Form 10AB and selecting in-applicable section code instead of filing Form 10A with appropriate section code. Otherwise, the learned CIT(E) never disputed the fact that appellant-trust was in existence before 01.04.2021 and got provisional registration from the CPC. The learned CIT(E) has also not disputed the fact that appellant-trust has filed application in Form 10AB before the due date provided for filing such application as notified by the CBDT which is up-to 30.06.2024. No doubt, the appellant-trust should have filed Form 10A and opted for section code 12A(1)(ac)(i) instead of sec. 12A(1)(ac)(iv) for registration....