2025 (10) TMI 1223

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....ndent : Shri AR.V. Sreenivasan, CIT O R D E R PER MANU KUMAR GIRI, JM: The captioned appeal filed by the assessee is directed against order of the Ld. Commissioner of Income Tax (Exemption), Chennai, ['CIT(E)' in short] dated 17.03.2025 rejecting the application filed by the assessee dated 30.09.2024 in Form No.10AB under clause (iii) of first proviso to section 80G(5) of the Income Tax A....

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....hted that the assessee submitted an application in accordance with clause (iii) of the first proviso to sub-section (5) of Section 80G of the Act. According to the previous regulations, the application needed to be submitted by September 2023, which is six months before the conclusion of the provisional approval period that ends on 31.03.2024. Following this, the CBDT released Circular No.7/2024 o....

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....pproval be granted effective from 01.10.2024, which is the date when the amended provisions under clause (iv) of Section 80G(5) take effect. The ld. AR also referred the order of the co-ordinate Bench of Tribunal in the case of Aalayam Vs The CIT(E) ITA No.1012/Chny/2025 dated 25.07.2025 and order of the Mumbai Bench of the Tribunal in the case of Chetana Vs CIT(E) [2025] 176 taxmann.com 713 (Mumb....

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.... No.7/2024 dated 25.04.2024. However, it is important to note that clause (iv) has been added to the first proviso to Section 80G(5) by the Finance Act, 2024, effective from 01.10.2024, allowing the assessee trust to apply for approval under section 80G(5) at any time following the commencement of its activities. This new provision is separate from clause (iii), which governed the previous timelin....