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2025 (12) TMI 1917

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.... Rajakumar, Adv For the Revenue : Ms. Nimisha Singh, CIT DR ORDER PER M. BALAGANESH, A. M.: 1. The appeal in ITA No. 2335/Del/2025, arises out of the order of the ld Commissioner of Income Tax (Exemptions), Chandigarh [hereinafter referred to as 'ld. CIT(E)', in short] dated 21.03.2024 against the revenue of registration of trust u/s 12A(1)(ac)(iii) of the of the Income-tax Act, 1961 (....

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....istration u/s 12AA of the Act on 28.09.2016 and granted registration thereon on 28.09.2016. The CIT(E) noticed on perusal of the financial statement of the assessee for FYs 2020-21, 2021-22 and 2022-23 that main source of the income of the assessee society is agricultural income, Dharamsala receipts, interest income from bank and rent. It was submitted that the assessee owns a building which has 1....

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....55/- Rs. 90,762/- 5. The ld CIT(E) had noted that the assessee have been deriving surplus year on year and the amount expended towards charity is nominal. Ld CIT(E) also noted that the assessee had sold some of the land and had made profit thereon. Further, the assessee had made some cash deposit on 08.04.2021, 21.04.2021, 31.05.2021, which cannot be directly linked with the income disclosed....

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....ant of registration u/s 12AB of the Act. It is pertinent to note that the assessee is already registered u/s 12AA of the Act from 28.09.2016 onwards. Pursuant to the change in the Act, the assessee had applied for seeking permanent registration u/s 12AB of the Act. The department had already examined the genuineness of the charitable activities of the assessee society while originally granting reg....