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Facts
The assessee preferred an appeal against the order of the Ld. Commissioner of Income-tax (Exemption) rejecting its application for conversion of provisional registration into final registration. The rejection was based on the observation that necessary documents were not filed, impacting the genuineness of charitable activities.
Held
The Tribunal restored the issue to the files of the Ld. CIT(E) to provide the assessee an opportunity to file relevant documents and information, as the orders of the CIT(E) were silent regarding the mode of service of notices and knowledge of the assessee.
Key Issues
Whether the assessee was given adequate opportunity to present documents proving the genuineness of its charitable activities before rejection of its application for registration?
Sections Cited
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Income Tax Appellate Tribunal, DELHI BENCHES: G : NEW DELHI
Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL
Assessment Years: 2024-25 Saurabh Mittal Foundation, Vs Ward Exemp 2(1), D-49, Second Floor, Delhi. Sarita Vihar, Madanpur Khadar Mark, Delhi – 110 076. PAN: AACBS5303G (Appellant) (Respondent) Assessee by : Shri Rohit Kapoor, Advocate & Shri Vir Singh, Advocate Revenue by : Shri Mahesh Kumar, CIT-DR Date of Hearing : 03.07.2025 Date of Pronouncement : 18.07.2025 ORDER PER ANUBHAV SHARMA, JM:
This appeal is preferred by the assessee against the order dated 27.08.2024 of the Ld. Commissioner of Income-tax (Exemption), New Delhi, rejecting application in Form 10AB for conversion of provisional registration into final registration dated 20.02.2024.
On hearing both the sides, we find that while passing the impugned order, the ld. CIT(E) has observed that necessary documents were not filed leading to a conclusion that the genuineness of the charitable activities is not established.