2025 (2) TMI 1604

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....ised the following grounds of appeal: 1. "Non-granting of Benefit under Section 11/12 On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in not allowing the benefit of Section 11/12 of the Income Tax Act, 1961, to the Appellant despite the Trust being duly registered under Section 12A/12AA of the Act, which is wrong and contrary to the facts and circumstances of the case and the reasons assigned for doing so are contrary to the provisions of the Income Tax Act, 1961 and the Rules made thereunder. 2. Misinterpretation of Filing Requirement under Section 12A(1)(b) On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in holding that the Appellant was requir....

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....the period allowed for filing a return of income under Section 139(4), as held in multiple judicial pronouncements. 6. Condonation of Delay in Filing Form 10B On the facts and in the circumstances of the case and in law, the learned CIT(A) erred in not condoning the delay in e-filing Form 10B, even though the audit of accounts was completed on 31/12/2020 and the audit report was e-filed on 15/02/2021. The delay was attributable to operational disruptions during the pandemic and lack of familiarity with compliance requirements, which constitutes a reasonable cause for condonation as per CBDT Circular No. 16/2024 and judicial precedents. 7. Violation of Principles of Natural Justice On the facts and in the circumstances of t....

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....g Officer ('ld. A.O.' for short)/CPC vide intimation dated 30.11.2021, u/s. 143(1) of the Act, determined the total income of the assessee u/s. 11 of the Act. Subsequent to this, the assessee filed rectification application u/s. 154 of the Act, dated 13.12.2021. Parallelly, the assessee preferred the appeal before the ld. CIT(A), who vide order dated 21.10.2024, dismissed the appeal filed by the assessee on the ground that the assessee had filed form 10AB with a delay of 30 days from the date of filing of the return of income. 4. Aggrieved the assessee is in appeal before us, challenging the impugned order of the ld. CIT(A). 5. We have heard the rival submissions and perused the materials available on record. It is observed th....