SHREE SAURASTRA GURJAR SUTAR VISHVAKARMA PARIVAR,AHMEDABAD vs. CIT(E), AHMEDABADA, AHMEDABAD

The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Exemption), Ahmedabad [hereinafter referred to as ‘CIT(E)’] dated 29/08/2025.

The assessee, in this appeal, is aggrieved against the action of the Ld. CIT(E) in rejecting the application of the assessee for registration u/s.12A of the Income Tax Act, 1961 (in short “the Act”). Shree Saurastra Gurjar Sutar Vishvakarma Parivar vs. CIT(E) Asst. Year : 2026-27

The appeal is time-barred by 48 days. A separate application for condonation of delay has been filed, wherein, it has been pleaded that the assessee had applied for final registration under sub-clause (iii) of clause (ac) of sub-section (1) of Section 12A of the Act, by filing the application in Form 10AB of the Act on 24/02/2025. It has also been pleaded that thereafter, the Ld. CIT(E) called for necessary details from the assessee-trust. However, the Ld. CIT(E) after going through the said details, dismissed the application of the assessee. It has been further pleaded that the Consultant of the assessee was extremely busy with statutory compliances relating to Tax Audit Reports and Income Tax Returns during the peak filing season and could not file the present appeal in time. The reason for condonation of delay does not constitute sufficient reasons for the purpose of condoning the delay in filing the application.

The fact on the file is that the assessee was not enjoying any original registration, entitling the assessee to file the application for final/regular registration. The Ld. CIT(E) noted that since the assessee was never granted the provisional registration, therefore, there was no question for granting the final/regular registration. He, accordingly, rightly dismissed the application of the assessee for final registration.

We have been further apprised that after dismissal of the application of the assessee vide impugned order of the Ld. CIT(E), the assessee again applied for provisional registration to the Ld. CIT(E) which has already been granted to the assessee vide order dated 10/02/2026 applicable from AYs 2026-27 to 2029-30. The assessee fully aware of the fact that the assessee’s application for final registration was rightly dismissed by the Ld. CIT(E), applied afresh for provisional registration, which has been duly granted to Shree Saurastra Gurjar Sutar Vishvakarma Parivar vs. CIT(E) Asst. Year : 2026-27 the assessee. Therefore, no case is made out in the present appeal of the assessee and the same is, accordingly, dismissed.

In the result, the appeal of the assessee stands dismissed.