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2025 (4) TMI 2165

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....e Income Tax Act, 1961 (the "Act"). "1. On the facts and circumstances of the case and in law the Ld.CIT erred in not granting registration u/s 12AC on the ground of not having been satisfied about the charitable nature of activities of the trust or genuineness of its activities in spite of the fact that : a. The appellant trust is exclusively engaged in charitable activities and b. The appellant having submitted all documents as called for by the Ld.CIT in this respect." Submission of ld.AR : 2. Ld.AR for the Assessee filed paper book containing 263 pages. Ld.AR submitted that all these details were filed before the ld.CIT(E), however, without verifying these documents, ld.CIT(E) has rejected the applicatio....

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....e application should not be rejected and why the approval granted under section 12AB of the Income Tax Act, 1961 should not be cancelled. The assessee was also given opportunity of being heard vide the said notice. The assessee was specifically informed that in the event of failure to comply by the due date, the application shall be liable to be rejected and the approval shall also be liable to be cancelled. The compliance to the said notice was due on 02/09/2024. The notice was duly served on the assessee through e-portal and email. 6. The assessee submitted the documents on 02/09/2024. However, the assessee's contention is not acceptable. 7. Further, without prejudice to the above and as per financial statements and ....

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.... 14. DONATIONS-RECEIPTS-2_Optimized 15. VOUCHER_2021-22_Optimized 16. VOUCHER_2022-23_Optimized 17. BANK STATEMENTS 18. NOTES ON ACTIVITIES 19. 10AC SELF CERTIFIED 9. We have perused copy of return of income for A.Y.2023-24 and noted that assessee had not claimed any exemption u/sec.11 of the Act for A.Y.2023-24. In the Return of Income, Assessee has specifically claimed exemption u/sec.10(23C)(iiiad) of the Act. The relevant pages scanned and reproduced as under : 10. Thus, on perusal of the Return of Income for A.Y.2023-24, it is observed that the findings recorded by ld.CIT(E) is incorrect. Similarly, we have perused the Return of Income for A.Y.2022-23 and it is observed that Assess....

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....ject of Self-Employment which was reported in the local newspaper(page 158 of the paper book). Similarly, other charitable activities reported in the local newspapers can be observed from the paper book. Assessee has also submitted copy of the Audit Report filed before Charity Commissioner as per Maharashtra Public Trust Act, which gives list of educational institutes. 14. Nowhere in the order ld.CIT(E) has doubted the genuineness of activities. 15. In these facts and circumstances of the case, we are convinced that assessee is a charitable trust carrying out charitable activities as defined in Section 2(15) of the Act. Therefore, Assessee is eligible for registration u/sec.12A(1)(ac) of the Act. Accordingly, we direct ld.CIT(E) to gr....

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....ae) 2d . 2€ Exemption under section 10(230) 20 @ 21 Exemption under section 10(23DA) 21 · 2g Exemption under section 10(23FB) 2g @ 2m Exemption under section 10(24) 2₼ 0 21 Exemption under section 10(46) 21 . 21 Exemption under section 10(47) 21 0 3 Income chargeable under section 11(3) read with section 10(213. [Total of Col. 15 of schedule !! 3 . 4 Income claimed as exempt under section 13A in case of a Political Party. 4 @ Income claimed as exempt under section 138 in case of an Electoral Trust. (item No. 6vil of Schedule 5 0 5 ET) 6 Voluntary Contribution received during the year . . @ 1 Heads of income 1 . Income from house property [4 of Schedule HP] (enter nit if loss) . ....

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..... 10/2300). 10:24). 10(46). 10647) 2# Exemption under section 12:23C)dat) 2ª . - Exengton under section 10.23C)-ac) DEPARTMENT 2 · 2 COME Exemption under section 10:23℃)-4af) 20 73.40.01# 20 TAX Exengros under section 10:23Cx(444| 24 · 2 Exemption under section 10:230; 2# · - Exemption under section 1OG230A) 20 · 7% Exenyton under section 10(23/ 0) 29 . 2 Exempton under section to024) 2 · a Exenyson under section 10008 2 . 2 Exengton under section 10(47) · ₴ 7340 ... # 3 4 $ . 7 Amount ekgbie tur exongron unter any other cause of section 1@ jother than those at 1 and 2) 3 . Icone chargescie under section 11(3) root with section 10021). [Tural of Col 13 al Sched/e 4 . Icone canel as e....