2025 (11) TMI 338

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....a Choudhury, Advocate For the Revenue : Shri Sanat Kumar Raha, CIT-DR ORDER PER RAJESH KUMAR, AM : These two appeals are filed by the assessee against the order passed by the ld. Addl./JCIT(A)-2, Ludhiana, both dated 06.03.2025, for the assessment years 2020-2021 & 2023-2024. 2. In both the appeals, the ld. AR submitted that the assessee is a trust and filed its return of income 7cl....

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....er the Act, which has not been done by the assessee. Therefore, ld. CIT-DR submitted that the ld. CIT(A) has rightly rejected the claim of the assessee on account of late filing of Form 10B/10BB and prayed for upholding the same. 4. After hearing the rival contentions and perusing the material available on record, we find that the assessee has filed its return of income on 27.03.2021 for A.Y.20....

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.... conditions are required to be satisfied which were not fulfilled by the assessee. It is noticed that the audit report was very much available with the Assessing Officer when the returns of income were processed and this is only a technical/procedural breach. The coordinate bench of the Tribunal has been holding that such technical lapse cannot lead to denial of exemption u/s. 11 & 12 of the Act t....