2025 (10) TMI 1211

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....s a delay of 793 days in filing of this appeal. A condonation application has been filed along with affidavit of Shri Patel Kamleshbhai Jayantibhai, trustee of the assessee-trust. It has been explained that the assessee was granted provisional registration for the period from AYs 2022- 23 to 2026-27. Thereafter, it had filed an application in Form No.10AB for the Act for approval u/s. 80G(5) of the Act. It has been explained that the notices were sent by the Ld. CIT(E) on the email Id of the assessee which was not regularly accessed. As a result, neither any compliance could be made nor the assessee was aware of rejection of application by the Ld. CIT(E). It was only when the intimation u/s. 143(1) of the Act for AY 2024-25 was received wit....

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.... appellant. The impugned order being a non-speaking order, it is liable to be quashed and set aside. 2.1 The Ld CIT(A) has grievously erred in law and or on facts in upholding that the interest income of Rs. 27,67,420/- on the investment of funds not belonging to the Appellant Corporation was chargeable to tax in the hands of the appellant though the refund of tax did not belong to the appellant. 2.2 That in the facts and circumstances of the case as well as in law, the Id. CIT(A) ought not to have held that the refund of income tax belongs to the appellant and as such corresponding income had accrued to him. 2.3 The Ld CIT(A) has grievously erred in law and or on facts in upholding that since no appeal was filed ....

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....- upon the assessee which should be deposited into "Prime Minister National Relief Fund" within a period of 15 days from the receipt of this order. 9. A copy of Form No.10AB filed by the assessee has been brought on record in the paper book filed. It is found from there that at Sr.No.27a. the assessee has stated 'NO' to the query "Whether the fund or the institution has incurred any expenditure of religious nature?". While denying any expenditure of religious nature, the assessee at Sr. No.27b. had provided the following details for three previous years' expenditure as under: Sr. No Financial Year Total Income Expenditure of Religious Nature Percentage to Total Income (%) 1. 2020 Rs. 25,500 Rs. 25,450 99.8 ....