PURN PRAKASH TRUST,NEW DELHI vs. CIT EXEMPTION, DELHI

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ITA 5956/DEL/2024Status: DisposedITAT Delhi25 June 2025Bench: MS. MADHUMITA ROY (Judicial Member), SHRI KHETTRA MOHAN ROY (Accountant Member)1 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the assessee had submitted all necessary documents and evidences, both to the lower authorities and in the paper book. It noted that the trust was registered late from 23.03.2017 under Section 12AA and Section 80G, with no change in its objects or activities.

What were the facts?

The assessee, Purn Prakash Trust, filed an appeal against the order of the CIT(E) denying registration under Section 12A(1)(ac)(iii) of the Act. The CIT(E) rejected the application, citing failure to submit necessary evidences.

What were the issues?

Whether the CIT(E) erred in rejecting the application for registration u/s 12A(1)(ac)(iii) of the Act despite the assessee providing sufficient evidence of its charitable objects and activities.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 12A,Section 12AA,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “F” BENCH, DELHI

Before: MS. MADHUMITA ROY & SHRI KHETTRA MOHAN ROY

For Appellant: Ms. Sweeti Kothari, CA
For Respondent: Ms. Monika Singh, CIT, DR
Hearing: 05.06.2025Pronounced: 25.06.2025

The instant appeal preferred by the assessee is directed against the order dated 29.11.2024 passed by the Ld. CIT(E), Delhi denying registration u/s 12A(1)(ac)(iii) of the Act. The assessee has raised the following grounds:

“1. The learned CIT(Exemption) has erred in law and on facts in rejecting the application filed for grant of registration u/s 12A(1)(ac)(iii) of the Act and consequentially cancelling the provisional registration ignoring the facts and evidences placed on record to substantiate the objects being Purn Prakash Trust charitable, genuineness of the activities and commencement of activities. Thus, the directions should be issued to grant registration u/s 12A(1)(ac)(iii) of the Act.

2.

The appellant craves the leave to add, substitute, modify, delete or amend all or any ground of appeal either before or at the time of hearing.”

2. At the very onset, we note that the registration has been denied by the CIT(E) holding that the assessee has failed to submit necessary evidences. We find the assessee has time and again submitted all necessary documents and evidences and the same is also submitted before us by way of paper book: Purn Prakash Trust

3. We find that the trust was registered late from 23.03.2017 under Section 12AA and Section 80G there is no change in the objects and the activities of the trust. It is also not the case that appellant has failed to file the documents as evidenced from the paper book. Therefore, we allow that the registration be granted to the trust under Section 12A on the strength of the evidences submitted.

4.

The appeal of the assessee is allowed.

Order pronounced in the open court on 25.06.2025

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