2025 (11) TMI 25

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....er. This common order is to dispose of the above captioned both appeals, as common issue based on same facts is involved, and both appeals have been argued simultaneously. 2. Arguments heard. Files perused. 3. As per record, vide order dated 27.11.2024, Learned CIT(E) rejected two applications of the appellant-appellant i.e. one u/s 12A(1)(ac)(B) of the Income Tax Act, 1961 (hereinafter r....

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....prayer is that impugned orders be set aside. 7. Para 2.4 of the impugned order, relating to the rejection of the application u/s 12AB, contains following observations made by Learned CIT(E):- "i) The applicant has not furnished details of activities carried during the F.Y. 2021-22, 2022-23 except one activity to help of elderly parents and wives of Army person during second wave of Cor....

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....ctivity bill vouchers, photos has been provided by the applicant. Therefore, from the above discussion, it is held that as per the reply/documents submitted the applicant's activities are non-genuine thus application for registration u/s 12A is liable to be rejected." 8. Ld. AR for the appellant is right in submitting that even if the applicant society carried out only one activity to help elde....

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.... cause notice dated 07.11.2024. However, in the paper book, we do not find copy of any bills/voucher. In view of the copies submitted before this Appellate Tribunal in the form of paper book (from page 4 to 12), it cannot be said that the entire information/details/documents, as desired vide show cause notice dated 07.11.2024 were made available to Learned CIT(E). 11. In the given situati....