2025 (2) TMI 1377

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.... the Revenue : Mr. R.A.Dhyani, CIT-DR ORDER PER NARENDER KUMAR CHOUDHRY, JM: This appeal has been preferred by the assessee against the order dated 29.11.2024, impugned herein, passed by the ld. Commissioner of Income Tax (Exemptions), Mumbai (in short 'Ld. Commissioner'). 2. In the instant case, the assessee being a charitable organization was provisionally registered u/s.12A & 80G of....

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....essee, in response to which, the Assessee vide letter dated 08.11.2024 claimed that the assessee has not carried out any religious activity and all activities are of charitable activities. 4. The ld. Commissioner though considered the submission of the Assessee, but could not find sufficient and necessary compliance, as per the provisions of the Act and thus ultimately held the object no. 3(23)....

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....see had replied the final show cause notice on 08.11.2024 and, therefore, construed that its case for approval u/s.80G(5) of the Act has been ascertained. However, the ld. Commissioner without raising any specific objection qua violation of statutory provisions and/or giving any further opportunity of being heard, rejected the application, vide impugned order and therefore, the impugned order is l....

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....ied with the show cause notice dated 13.11.2024, however, by filing its reply on 18.11.2024 submitted a letter dated 17.11.2024 before the Ld. Commissioner and claimed that it has not carried out any religious activities and all activities carried out are of charitable activities. 7.1 We have given thoughtful consideration to the observation of ld. Commissioner and claim made by the Assessee. W....