RANG AMARNATH SEVA TRUST CHHOTAUDEPUR,CHHOTAUDEPUR vs. COMMISSIONER OF INCOME TAX (EXEMPTION), AHMEDABAD

PER SUCHITRA KAMBLE, JUDICIAL MEMBER:

These two appeals are filed by the Appellant Trust against two separate orders, dated 13.11.2024, & 15.11.2024 respectively, passed by the CIT(E), Ahmedabad for Assessment Year 2025-26 for both.
2. The Appellant Trust has raised the following grounds of appeal:

ITA No.7/Ahd/2025 for Assessment Year 2025-26
“Being aggrieved by the order dated 13.11.2024, u/s.12AB(1)(b) of the Income
Tax Act, 1961 (Hereinafter referred as "The Act"), rejecting the application filed in form 10AB, for registration u/s.12A(1)(ac)(iii) of the Act, by the Commissioner of Income Tax (Exemption), Aayakar Bhawan (Vejalpur), Ahmedabad,
(hereinafter referred as "CIT(Exemption)"), the appellant has preferred this appeal on the following grounds:

ITA Nos.7 & 8/Ahd/2025
Assessment Years: 2025-26 for both
1. On facts and circumstances of the case and in law, the order passed by the Hon'ble CIT(Exemption), rejecting the application filed in form 10AB, for final registration u/s.12A(1)(ac)(iii) of the Act, is bad in law.
2. On facts and circumstances of the case and in law, the order passed by the Hon'ble CIT(Exemption), cancelling the provisional registration of the appellant, for registration u/s.12A(1)(ac)(vi)(A) of the Act, is bad in law.
3. On facts and circumstances of the case and in law, the order passed by the Hon'ble CIT(Exemption), directing the appellant to compute the tax liability u/s.115TD of the Act read with rule 17B of the IT Rules, is bad in law.
4. Your appellant prays for leave to add, alter and/or amend/withdraw any and /or all the grounds of appeal adduced above.”

ITA No.8/Ahd/2025 for Assessment Year 2025-26
“Being aggrieved by the order dated 15.11.2024, rejecting the application filed in form 10AB, for registration u/s.80G(5)(iii) of the Income Tax Act, 1961
[Hereinafter referred as "The Act") of Commissioner of Income Tax
(Exemption), Aayakar Bhawan (Vejalpur) Ahmedabad, (hereinafter referred as "CIT Exemption)"), the appellant has preferred this appeal on the following grounds:
1. On facts and circumstances of the case and in law, the order passed by the Hon'ble CIT (Exemption), rejecting the application filed in form 10AB, for final registration u/s. 80G(5)(iii) of the Act, is bad in law.
2. Your appellant prays for leave to add, alter and/or amend/withdraw any and for all the grounds of appeal adduced above.”
3. The appellant Trust has filed application for registration of Trust in Form 10AB under Sub-Clause(iii) of Clause (ac) of Sub-Section (1) of Section 12A of the Income
Tax Act, 1961 as well as application for approval under Clause (iii) of First Proviso to Sub-Section(v) of Section 80G of the Income Tax Act, 1961. The CIT(Exemption) vide order dated 13.11.2024 and 15.11.2024 rejected both the applications and cancelled the provisional registration of the Trust and not granted approval under Section 80G of the Act.
4. Being aggrieved by the rejection, the appellant Trust filed appeals before us.
5. The Ld. AR submitted that the CIT(E) has not given any substantial finding and has not considered the documents filed by the assessee. Therefore, the Ld. AR

ITA Nos.7 & 8/Ahd/2025
Assessment Years: 2025-26 for both
PBN/*
Copies to:
(1)
The appellant
(2)
The respondent

(3)
CIT

(4)
CIT(A)

(5)
Departmental Representative

(6)
Guard File

By order