2025 (9) TMI 1015

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....ounds have been taken in this appeal: - "1. The Ld. CIT(Exemptions) has erred in rejecting the application filed by Appellant Trust on the ground that application filed in Form 10AB has not filed within time limit prescribed and therefore it is non maintainable. On facts and circumstances of the case the action of Ld. CIT (Exemptions) 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 sub-section (1) of section 12A instead of the correct code, which is sub-clause (iii) of clause (ac) of sub-section (1) of section 12A. 3. ....

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....he Act was selected in place of the correct code, which was sub clause (iii) of clause (ac) of sub- section (1) of section 12A of the Act. The Ld. AR submitted that the assessee is engaged in charitable activities and it may be allowed an opportunity to rectify the inadvertent mistake in the application and for this purpose 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 Sher Singh, 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 ....