2025 (2) TMI 1583

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....istration u/s 12AB of the Act respectively. 2. Since both the captioned appeals were heard together and pertain to same assessee, they are disposed of by this common order for the sake of convenience and brevity. 3. Representatives of both the sides were heard at length. Case records carefully perused. Relevant documentary evidence brought on record duly considered in light of Rule 18(6) of the ITAT Rules. ITA No. 3457/DEL/2024 4. Briefly stated the facts of the case are that the assessee is a trust incorporated on 22.12.2021. The company was established to promote, establish, open, set up, maintain, assist, support and run, in India educational institutions like schools, colleges, coaching classes, practical training class....

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....sional registration issued on 10.03.2022. 8. The assessee is aggrieved and has come in appeal before us and submitted that the ld. CIT(E) did not consider the reply of the assessee nor its annexures and passed order. The ld. CIT (A) was not right in rejecting the application of the assessee for registration u/s 12A of the Act. 9. Per contra, the ld. DR relied upon the orders of the ld. CIT(E). 10. We have given a thoughtful consideration to the order of the CIT (Exemption). We find that the assessee has filed several documents and evidences before us, which were filed by the assessee before the CIT(E), to establish the genuineness of the activities of the trust. We find that the assessee has also filed the necessary approvals from ....

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....t genuine; and that non-production of books does not mean that the genuineness of the charitable activities of the assessee society is not established. Reliance in this regard may be placed on Vidyadayani Shiksha Samiti vs. CIT ITA No. 309/Del/2016 order dated 14.12.2017; Bhartiya Kisan Sangh vs. CIT - (2017 59 ITR (Trib) 228 (ITAT-Del); Shanti Education and Welfare Society vs. CIT ITA No. 5970/Del/2012; Fifth Generation Education Society - 185 ITR 634; CIT vs. Babu Ram Education Society - (2018) 96 taxmann.com 606 (Allahabad); CIT vs. B.K.K. Memorial Trust - (2013) 256 CTR 424; and DIT (E) vs. PannaLalbhai Foundation - 216 taxman 148. 11. Hon'ble Karnataka High Court in CIT vs. A.S. Kupparaju Brothers Charitable Foun....