2025 (9) TMI 1365

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....of the Income-tax Act, 1961 (for short, "the Act"). The assessee trust has assailed the impugned order on the following grounds of appeal before us: "Ground 1. The Rejection order dated 17-03-2025 in Form 10AD of the Income-tax Act, 1961 is erroneous and contrary to law and facts of the case and devoid of any merit. Ground 2. The CIT(E), Hyderabad failed to note that the amendments in Finance Act 2020 were introduced to simplify the procedure of registration of charitable trusts/Institutions and the amendments cannot be interpreted in a way that is prejudicial to the Trust/Institutions. Ground 3. The CIT(E), Hyderabad failed to issue show cause notice and provide opportunity of being heard regarding delay in filin....

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....e assessee is a trust registered with the Registrar of Trusts on 19.07.1995, with its primary objects as that of relief of the poor, education, and medical relief. The assessee trust was granted provisional registration under Section 80G of the Act by the Central Processing Centre (CPC) in "Form No. 10AC" dated 22.06.2022, valid for the period from AY 2023-24 to AY 2025-26. 3. The assessee trust in accordance with the provisions of the amended Section 80G and Rule 11AA, had filed its application for regular registration in "Form No. 10AB" on 30.09.2024. During the course of proceedings under Section 80G(5)(iii), the assessee trust vide its replies dated 29.12.2024, 28.02.2025, and 17.03.2025 submitted the requisite details/information in....

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....nd not deliberate. The Ld. AR submitted that the assessee trust had already been granted provisional registration and had thereafter complied with all statutory requirements. Elaborating further on his contention, the Ld. AR submitted that the delay in filing the application for regular registration was only procedural and should not defeat the substantive claim under Section 80G of the Act. The AR also contended that the assessee trust had filed complete details before the CIT(Exemptions), which demonstrated the genuineness of its activities. 9. Per Contra, the learned DR supported the order of the CIT(Exemptions) and submitted that the time limit prescribed under the law is mandatory in nature, and the CIT(Exemptions) has no discretion....