2026 (6) TMI 341

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....y application for grant of 80G registration was rejected. 2. We have heard the rival contentions of both parties; subject to provisions of rule 18 of Income Tax Appellate Rules, 1963 ['ITAT Rules' hereinafter] perused material placed on records. 3. We note that; a. The assessee is a registered public trust carrying on religions, educational and charitable activities and has been holding a certificate of registration u/s 12A of the Act and a certificate of provisional registration u/s 80G of the Act issued to it by an order dt. 27/05/2021 valid for the AY 2021-22 to 2023-24. b. For seeking 80G regularisation, the assessee trust filed an application to the respondent vide application No. CIT EXEMPTION.BHOPAL/2023-24/12....

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.... cancel the provisional registration granted earlier and to reject the application made for regular registration/approval u/s 80G(5) of the Act. 5. The matter of fact as solidified by the Ld. DR from Pg. 6 of impugned order is that, the computation of religious expenditure found exceeding the ceiling was never confronted to the assessee for rebuttal as the said computation is devoid of merits. It the case of the assessee that, in the course of proceedings before Ld. CIT(E) the audited financial statements and audit reports for latest three years were adduced. The computation arrived by the Ld. CIT(E) when cross checked with records revealed to the appellant that, certain non-religious expenses considered. Therefore, the computational err....