2025 (9) TMI 23

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.... which was filed by the assessee online on 13.01.2024 in Form No.10AB u/s. 12A(1)(ac)(iv) of the Act. 2. At the outset, the Ld.AR of the assessee brought to our notice that appeal has been filed belatedly after '94' days and the assessee has filed an affidavit explaining the cause of delay. Having gone through the contents of the application and the affidavit filed by the assessee, we find that there is reasonable cause for delay which we excuse and proceed to adjudicate the appeal on its merits. 3. The brief facts brought to our notice by the Ld.AR of the assessee are that the assessee is an Educational Trust, which was granted registration u/s. 12AA of the Act on 31.01.2017 and therefore, assessee-Trust was an old Trust enjoying registr....

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....hat assessee is an Educational Trust which was engaged in charitable activities which paved way for it being granted registration u/s. 12A of the Act on 31.01.2017 and therefore is noted to be an old Trust enjoying the registration u/s. 12A of the Act from AY 2017-18 onwards which registration assessee would have enjoyed for perpetuity, but for the amendment brought in the Act regime w.e.f. 01.04.2021 which brought in new regime & new procedure was required to be followed by old Trust enjoying registration u/s. 12A/80G of the Act as well as Trusts which was applying for registration u/s. 12 of the Act. In the present case, we note that assessee being an old Trust, pursuant to the new regime, the assessee ought to have filed its application ....