STUDENT AID SOCIETY,PANJAB UNIVERSITY vs. CIT EXEMPTIONS, CR BUILDING
1
IN THE INCOME TAX APPELLATE TRIBUNAL
‘B’ BENCH, CHANDIGARH
HYBRID HEARING
BEFORE HON’BLE SHRI LALIET KUMAR, JM
AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM
आयकर अपील सं. / ITA No.493 /CHANDI/2025
Student Aid Society
PU Campus, Punjab University
Sector 14, Chandigarh-160014. बनाम/
Vs.
CIT (Exemption)
Sector 17-E
Chandigarh.
̾थायीलेखासं./जीआइआरसं./PAN/GIR No. AAGTS-5630-N
(अपीलाथŎ/Appellant)
:
(ŮȑथŎ / Respondent)
अपीलाथŎकीओरसे/ Appellant by : Ms. Rajni (CA) & Shri Anil Arora (CA) – Ld. ARs
ŮȑथŎकीओरसे/Respondent by :
Smt. Kusum Bansal (CIT) – Ld. DR (virtual)
सुनवाईकीतारीख/Date of Hearing
:
29-07-2025
घोषणाकीतारीख /Date of Pronouncement
:
04-08-2025
आदेश / O R D E R
Manoj Kumar Aggarwal (Accountant Member)
Aggrieved by the rejection of an application seeking registration u/s 12A(1)(ac)(iii) vide impugned order dated 11-02-2025 of Ld. CIT(Exemption), Chandigarh, [CIT(E)], the assessee is in further appeal before us. 2. Upon perusal of para-3.2 of the impugned order, it could be seen that the assessee had already commenced its activities on 03-03- 1976 when it applied for provisional registration to CPC on 06-05- 2024. However, this registration could be applied only when the assessee had not commenced its activities which was not the case. Accordingly, the registration application was rejected and also the 2
provisional registration was held to be bad in law. The Ld. AR has prayed that error occurred in understating the nuisances of new regime of registration which came into effect from 01-04-2021. 3. We find that the registration has been denied merely on technical grounds. The assessee enjoyed 12A registration under old regime.
The errors apparently occurred due to new regime of registration which provide separate mechanism for registration of old and new trusts. Nevertheless the principles of natural justice demand that the application of the assessee be considered under applicable / relevant clause and the registration should not be denied merely on technical grounds. Therefore we set aside the impugned order and direct Ld.
CIT(E) to pass fresh order after considering the application under correct / relevant clause.
4. The appeal stand allowed for statistical purposes.
Order pronounced on 04-08-2025. (LALIET KUMAR) (MANOJ KUMAR AGGARWAL)
JUDICIAL MEMBER ACCOUNTANT MEMBER
Dated: 04-08-2025. आदेश की Ůितिलिप अŤेिषत /Copy of the Order forwarded to :
1. अपीलाथŎ/Appellant
2. ŮȑथŎ/Respondent
3. आयकरआयुƅ/CIT
4. िवभागीयŮितिनिध/DR
5. गाडŊफाईल/GF