SHRI SATYANARAYAN SEVA SAMITI,NAYAGARH vs. CIT(EXEMPTION),BHUBANESWAR, BHUBANESWAR

It was submitted by the ld AR that the assessee has been granted registration u/s.12A of the Act vide order dated 19.03.2025. It was the submission that however, the registration u/s.80G of the Act has been rejected vide order dated 17.03.2025 i.e. two days prior to the grant of registration u/s.12A of the Act. It was the prayer that as the assessee has been granted registration u/s.12A of the Act, the assessee is liable to be granted registration u/s.80G of the Act.

In reply, ld. CIT-DR vehemently supported the order of the ld. CIT(E). It was the submission that the activities of the assessee are not Deed/MOA/AOA. It was the submission that the order of the ld. CIT(E) is liable to be upheld.

We have considered the rival submissions. A perusal of the facts in the present case clearly show that the ld. CIT(E) has adjudicated the application filed in form 10AB for registration u/s.80G of the Act two days prior to the grant of registration u/s.12A of the Act. Further a perusal of the order of the ld.CIT(E) shows that the order is not a speaking order, insofar as no details are coming out from the order of the ld.CIT(E). What are the activities of the trust which are not commensurate with the activities as per the objectives of the registered Deed of the assessee trust, has not been explained. This being so, in the interest of justice, the issues in this appeal are restored to the file of the ld. CIT(E) for readjudication afresh after granting the assessee adequate opportunity of being heard.