SONAI GLOBAL FOUNDATION,SANGLI vs. CIT EXEMPTION, PUNE
आयकर अपीलीय अिधकरण ”बी” Ɋायपीठ पुणेमŐ।
IN THE INCOME TAX APPELLATE TRIBUNAL
PUNE BENCHES “B” :: PUNE
BEFORE DR.DIPAK P. RIPOTE, ACCOUNTANT MEMBER
AND SHRI VINAY BHAMORE, JUDICIAL MEMBER
आयकर अपील सं. / ITA Nos.614 & 615/PUN/2025
िनधाᭅरण वषᭅ / Assessment Year: -
Sonai Global Foundation,
Office No.11 to 14, Shriram
Plaza, Ram Mandir Corner,
Sangli – 416416. Maharashtra.
V s.
The CIT(Exemption),
Pune.
PAN: ABHCS8830R
Appellant/ Assessee
Respondent / Revenue
Assessee by Shri Amol R. Kulkarni – AR
Revenue by Shri Abhinay Kumbhar – CIT(DR)
Date of hearing
07/05/2025
Date of pronouncement 23/05/2025
आदेश/ ORDER
PER DR. DIPAK P. RIPOTE, AM:
These two appeals filed by the assessee are against the separate orders of ld.Commissioner of Income Tax(Exemption), Pune under section 12A of the Income Tax Act, 1961 dated 15.01.2025 and order under section 80G of the Income Tax Act, 1961 dated
15.01.2025. These Two Appeals were heard together and are being disposed of by this common order. We treat appeal in ITA
ITA Nos.614 & 615/PUN/2025 [A]
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No.614/PUN/2025 as “lead case”. The Assessee in ITA
No.614/PUN/2025 has raised the following grounds of appeal :
“1. Commissioner of Income Tax (Exemptions) (hereinafter referred to as "the learned CIT(E)], Pune erred on facts in rejecting the registration u/s 12A of the Income Tax Act, 1961. 2. The appellant contends that; the matter be remanded back to the file of learned CIT(E) since CIT(E) rejected the application due to "non- compliance" of the notice and also without giving any further opportunity to the appellant to the compliance.
The appellant contends that; the matter be remanded back to the file of learned CIT(E) since CIT(E) rejected the application in haste when sufficient time was available to decide the application on merits.
The appellant craves / leave to add/modify/delete / amend all / any of the grounds of appeal.”
Submission of ld.AR :
Ld.AR filed a paper book containing 107 pages. Ld.AR submitted that ld.CIT(E) rejected the appeal of the Assessee only on the ground of non-compliance. Since Assessee failed to submit the details, ld.CIT(E) rejected the application. Ld.AR submitted that Assessee may kindly be provided one more opportunity to file details before the ld.CIT(E).
Submission of ld.DR :
Ld.DR for the Revenue submitted that sufficient opportunity was provided by ld.CIT(E), but assessee failed to file details.
ITA Nos.614 & 615/PUN/2025 [A]
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Assessee has not given any reason for not filing the details.
Therefore, the rejection order may be upheld.
Findings & Analysis :
We have heard both the parties and perused the records.
1 The relevant paragraph of Statement of Facts filed by the Assessee are reproduced here as under : 1. the appellant is a non-profit Company incorporated on 15-02- 2022 under Section 8 of Companies Act, 2013 vide CIN:U85300PN2022NPL208633. ……………………….
The appellant is primarily incorporated as CSR Arm of Sonai Infrastructure Private Limited whereby CSR obligation of Sonai Infrastructure Private Limited can be discharged by carrying out various charitable activities through the appellant.”
2 It is observed that assessee is registered under Section 8 of the Companies Act. The Certificate of Incorporation issued by