2025 (11) TMI 1297

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....sessment Year 2021-22. 2. The assessee has raised following grounds of appeal :- "1. The learned ADDL.JCIT(APPEAL] grievously erred in law and on facts in dismissing the appeal of the appellant Trust against illegal intimation u/s 143(1) passed by ld CPC when the appellant Charitable Trust was registered since 1975 and activity of running charitable dispensary was not in dispute. The ld ADDL./JCIT (A) erred in not appreciating that due to frequent amendment's in provisions of section 11/12, the appellant did file application for fresh registration which was granted only from A.Υ. 2022-23. The exemption u/s 11/1 of the Act ought not to be disallowed due to technicality of procedure when genuineness ss of activity is n....

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.... Rs. 20,00,880/- is patently wrong and against sanction of law. It be so held now and return of income be directed to be accepted in toto now. 6. Both the lower authorities failed adhere to principles of natural justice while making/confirming huge addition/disallowance by not properly considering the appellants explanations, grounds and submissions. The orders are thus illegal and invalid which needs to be quashed. It be so held now." 3. Briefly stated facts are that the assessee is a charitable trust registered under section 12A of the Act, and engaged in the activity of running a charitable dispensary. The assessee filed its return of income for the year under consideration on 02.03.2022 declaring NIL income and claiming refu....

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....ng of a charitable dispensary, have never been doubted by the Department. The Ld. AR submitted that the assessee had filed application for fresh registration on 29.03.2022 and was granted registration on 05.04.2022 but it was from Asst. Year: 2022-23 to 2026-27 and not for A.Y. 2021-22. The Ld. AR contended that the application for registration as above was filed on 29.03.022, which was well within the extended time allowed by CBDT from time to time vide Circular No: 16/2021 dated 29.08.2011 whereby time for filing application for registration u/s 12A from 30th June 2021 to 31st March 2022 and the CBDT Circular again extended time vide Circular No: 7/2024 dated 23rd April 2024 tο 30.06.2024. The Ld. AR, therefore, argued that the as....