“registration under section 12A”

Charitable TrustsSection 12ASection 12A2,527 judgments

The decision most relied on for registration under section 12A is ACIT v. Surat City Gymkhana (300 ITR 214), cited in 125 judgments on BharatTax.

Leading authorities on registration under section 12A

ACIT v. Surat City Gymkhana

300 ITR 214 · 2008 · Supreme Court

125

citing judgments

Once an institution receives registration under Section 12AA, the Assessing Officer must compute its income as per Section 11, focusing only on the application of income and not re-examining the charitable nature of its activities. The Supreme Court also clarified the meaning and scope of 'general public utility' under Section 2(15).

Ananda Social and Educational Trust v. CIT

426 ITR 340 · 2020 · Supreme Court

116

citing judgments

For registration under Section 12AA, the Commissioner (Exemptions) must examine the objects of the trust and the genuineness of its proposed activities, even if the trust has not yet commenced actual charitable activities or incurred expenditure.

Ahmedabad Urban Development Authority v. ACIT

396 ITR 323 · 2017 · High Court

108

citing judgments

Development authorities can continue to be regarded as existing for a 'Charitable Purpose' under Section 2(15) of the Income Tax Act, even after the introduction of the proviso to that section. The contention that such authorities automatically lose their charitable status due to the proviso is incorrect.

CIT v. Gujarat Maritime Board

295 ITR 561 · 2007 · Supreme Court

citing judgments

A statutory corporation undertaking activities that generate income qualifies as a charitable entity under Section 2(15) if its dominant object is general public utility and it is legally obligated to apply its income solely for that purpose, even if the activities appear to be in the nature of trade or business. Such an entity is entitled to registration under Section 12A and exemptions under Section 11.

CIT v. Dawoodi Bohra Jamat

364 ITR 31 · 2014 · Supreme Court

citing judgments

A trust's objects, even if based on religious tenets, can qualify as charitable for tax exemptions if its benefits are not exclusively restricted to a particular religious community or caste.

CIT v. Ahmedabad Rana Caste Association

140 ITR 1 · 1983 · Supreme Court

citing judgments

An object beneficial to a section of the public, as distinguished from an individual or group of individuals, qualifies as an object of general public utility under Section 2(15) and hence a charitable purpose. This applies even if the benefits are restricted to a specific caste, community, or professional group.

CIT v. Parma Nand

268 ITR 172 · 2004 · High Court

citing judgments

Whether there was sufficient cause for delay in making applications for registration under section 12A and 80G is always a question of fact, and contumacious conduct by the assessee must be established for levying penalty under section 271C for non-deduction of TDS.

Barendra Prasad Ray v. ITO

129 ITR 295 · 1981 · Supreme Court

citing judgments

When determining if an activity serves charitable purposes for tax exemption, the primary consideration is whether its predominant object is to make a profit or to carry out charitable activities.

Judgments citing registration under section 12A

Shri Kripalu Samadhi Mandir Trust, Kalol vs. The CIT (Exemp), Ahmedabad

In the result, both the appeals filed by the assessees are allowed for statistical purposes

ITA 1608/AHD/2025[2025-26]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2025-26

Bench: Ms.Suchitra Raghunath Kamble & Makarand V.Mahadeokarasstt.Year : 2025-26 Kripalu Muni Mandal Trust The Ito, Ward At Malav, Taluka Kalol Vs. Exemption. Dist: Panchmahal. Vadodara. Pan : Aaatk 7859 F Asstt.Year : 2025-26 Shri Kripalu Samadhi Mandir Trust The Ito, Ward At, Post Malav Taluka Kalol Vs Exemption. Malav, Kalol. . Vadodara. Pan : Aapts 9485E (Applicant) (Responent) : Shri Nishit Shah, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Rignesh Das, CIT-DR

Section 10Section 12ASection 12A(1)(ac)Section 80G(5)(iv)

registration regime prescribed under section 12A(1)(ac), both the assessees had filed their applications in Form No. 10A, pursuant to which provisional registrations under section 12A(1)(ac)(vi) and provisional approvals under section 80G(5)(iv) were duly granted for a period of three years, covering Assessment Years ... took the view that since the assessees had themselves opted for the provisions of section 10(23C)(iv), they could not simultaneously claim registration under section 12A. Without affording any opportunity to rectify the defect or to explain the inadvertent error, both the applications were rejected vide separate orders dated

Kripalu Muni Mandal Trust, Kalol, Panchmahal vs. CIT (Exemption), Ahmedabad

In the result, both the appeals filed by the assessees are allowed for statistical purposes

ITA 1607/AHD/2025[2025-26]Status: DisposedITAT Ahmedabad16 Oct 2025AY 2025-26

For Appellant: Shri Rignesh Das, CIT-DR

Section 10Section 12ASection 12A(1)(ac)Section 80G(5)(iv)

Kamalam Foundation, Ankleshwar vs. The Commissioner of Income Tax (Exemption), Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1584/AHD/2025[NA]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra Raghunath Kamble & Makarand V.Mahadeokarasstt.Year : - Kamalam Foundation The Cit(Exemption) Plot No.6011 Vs. Ahmedabad. Gidc Ankleshwar Ankleshwar, Bharuch 393 002 Pan : Aajck 1669 D (Applicant) (Responent) : Shri Hardik Mehta, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Rignesh Das, CIT-DR

Section 115TSection 12A

passed under section 12AB(1)(b)(ii) of the Income Tax Act, 1961 [hereinafter referred to as “the Act”], rejecting the application for registration under section 12A and cancelling the provisional registration earlier granted under section 12AB. 2. The assessee has raised the following grounds of appeal

Momin Samaj Federation, Ahmedabad vs. The CIT(Exemption), Ahmedabad

ITA 1381/AHD/2025[NA]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarmomin Samaj Federation The Cit C/401-402 Lotus Residency, (Exemption), Nr. Congress Bhavan, Paldi, Vs Ahmedabad Ahmedabad, (Respondent) Gujarat-380007 Pan: Aactm6412C (Appellant)

For Appellant: Mr. Varishusen Momin, A.RFor Respondent: Shri Rignesh Das, CIT-D.R

Section 12ASection 12A(1)(ac)

applicant/appellant Momin Samaj Federation, is a charitable trust engaged in activities for the welfare of the public. The trust applied for registration under Section 12A of the Income Tax Act, 1961 by filing Form 10AB under sub-clause (iii) of clause (ac) of sub-Section (1) of Section 12A ... recorded any finding on the genuineness of the activities. The CIT(E) in the absence of the required documents, rejected the application for registration under Section 12A and also cancelled the provisional registration granted earlier. I.T.A No. 1381/Ahd/2025 Momin Samaj Federation 4. Being aggrieved by the rejection order dated

Shree Dasha Porwad Gnyati Samast Panch Gam Mahamandal Trust, Pahchmahal vs. CIT (Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1276/AHD/2025[Not Applicable]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokarasstt.Year : - Shree Dasha Porward The Cit(Exemption) Gnyati Samast Panch Vs. Vejalpur Gam Mahamandal Trust Ahmedabad. Sapan Printers Station Road, Halol Godhra. Pan : Aatts 1886 K (Applicant) (Responent) Assessee By : Shri Manish Rajvaidya, Ar Revenue By : Shri Rignesh Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 15/10/2025 घोषणा क" तारीख /Date Of Pronouncement: 16/10/2025

For Appellant: Shri Manish Rajvaidya, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 12A

आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण,अहमदाबाद "यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद "यायपीठ अहमदाबाद "यायपीठ ‘C’ अहमदाबाद

Rotary Club Rajkot Prime, Rajkot vs. The CIT (Exemption, Ahmedabad

In the result, both appeals are dismissed

ITA 2089/AHD/2024[NA]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: NoneFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iii)

dated 21.11.2024 passed by the Commissioner of Income- tax (Exemptions), Ahmedabad [hereafter referred to as “CIT(E)”], rejecting the assessee’s applications for registration under section 12A(1)(ac)(iii) and for approval under section 80G(5)(iii) of the Income-tax Act, 1961 (“the Act”). Since the issues ... anytime up to the hearing of this appeal. 3. Facts in Brief : 3.1 The assessee had filed applications in Form No. 10AB seeking registration under section 12A(1)(ac)(iii) and approval under section 80G(5)(iii) of the Act. The learned CIT(Exemption) issued notices on various occasions calling

Rotary Club Rajkot Prime, Rajkot vs. The CIT (Exemption), Ahmedabad

In the result, both appeals are dismissed

ITA 2088/AHD/2024[NA]Status: DisposedITAT Ahmedabad16 Oct 2025

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

For Appellant: NoneFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iii)

Jan Kalyan Samiti, Patna vs. CIT Exemption, Patna

In the result, both the appeals of the assessee, being ITA Nos

ITA 88/PAT/2025[2022-2023]Status: DisposedITAT Patna15 Oct 2025AY 2022-2023

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.80 & 88/Pat/2025 Assessment Year: 2022-23 Jan Kalyan Samiti…………..….………. …………………....Appellant Khasmahal, Road No.3, Chiraiyatand, Patna – 800001. [Pan: Aaatj5412D] Vs. Cit (Exemption), Patna....…..……………..………………….…..... Respondent Appearances By: Shri Anjan Biswas, Fca, Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cit(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 13, 2025 Date Of Pronouncing The Order : October 15, 2025 आदेश / Order Per Sonjoy Sarma: Both These Appeals By The Assessee Are Directed Against The Orders Of The Learned Commissioner Of Income Tax (Exemption), Patna, Dated 26.12.2024, For The Assessment Year 2022–23. Since The Issues Involved In Both The Appeals Pertain To The Same Assessee & Arise Out Of Common Facts & Connected Applications, These Appeals Were Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience. 2. Ita No. 88/Pat/2025 Relates To Rejection Of The Application In Form No. 10Ab Filed By The Assessee Seeking Regular Registration Under Clause (Ac)(Iii) Of Sub-Section (1) Of Section 12A Of The Income-Tax Act, 1961 & Ita No. 80/Pat/2025 Relates To Rejection Of The Application In

Section 11Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)

purposes within the meaning of section 11 read with section 2(15) of the Act. Accordingly, the application in Form 10AB seeking regular registration under section 12A(1)(ac)(iii) and the corresponding application under section 80G(5) were rejected. 4. The learned Authorised Representative (AR) submitted that during

Jan Kalyan Samiti, Patna vs. CIT Exemption, Patna

In the result, both the appeals of the assessee, being ITA Nos

ITA 80/PAT/2025[2022-23]Status: DisposedITAT Patna15 Oct 2025AY 2022-23

Section 11Section 12ASection 12A(1)(ac)Section 2(15)Section 80GSection 80G(5)

Lakulish Sanatan Sanskariti Prabodhan Abhiyan, Vadodara, Gujarat vs. CIT Exemption, Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes, in the interests of justice

ITA 1367/AHD/2025[NA]Status: DisposedITAT Ahmedabad15 Oct 2025

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinha

For Appellant: Ms. Priya Sharma, AdvocateFor Respondent: Shri R P Rastogi, CIT-DR

Section 10Section 12ASection 253(5)

that the Commissioner must call for necessary documents and make due enquiry to satisfy himself about the genuineness of the institution before granting registration under section 12A of the Act. Further, CIT(Exemptions) placed reliance on the decision of the Hon’ble Supreme Court in M/s New Noble Educational Society

Nishkam Shewa Mandal, Ahmedabad vs. The CIT(Exemption), Ahmedabad

The appeal of the assessee is treated as allowed for statistical purposes

ITA 1051/AHD/2025[NA]Status: DisposedITAT Ahmedabad15 Oct 2025

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1051/Ahd/2025 िनधा"रण वष" /Assessment Year : N.A.

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Rignesh Das, CIT-DR

Section 12ASection 12A(1)(ac)

been filed, wherein, the assessee submitted the reason for such delay as under: “i. That the Applicant had preferred an application seeking registration under Section 12A(1)(ac) of the Act, before the Learned Commissioner of Income Tax (Exemptions). which came to be rejected vide order dated 22.10.2024, ex-parte

Deputy Commissioner of Income Tax, New Delhi vs. Odia Samaj, New Delhi

In the result Cross objections raised by assessee is allowed

ITA 5638/DEL/2024[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

Section 12ASection 133(6)Section 143(3)Section 144BSection 194CSection 194JSection 2(15)Section 80G

respect of event itself that it is not in accordance with the objects of the assessee trust for which revenue has granted registration under Section 12A of the Act or was involving any activity or any activity of rendering any service in relation to any trade, commerce or business. Even ... context of an event which is admittedly in concurrence with the objects of the assessee’s trust for which it has received registration under Section 12A of the Act, then mere fact that the tax has been deducted by the payers or invoice has been issued by the trust cannot

Roger Foundation, Agra vs. Commissioner of Income Tax ( Exemption) Agra, Agra

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 294/AGR/2025[2024-25]Status: DisposedITAT Agra13 Oct 2025AY 2024-25

Bench: Shri Sunil Kumar Singh & Shri Brajesh Kumar Singh

Section 12ASection 12A(1)(ac)

registration under Section 12AB of the Act. 2. Brief facts of the case are: The assessee had filed an application dated 28.09.2024 for registration under section 12A(1)(ac)(iii) of the Act in Form no. 10AB. The Ld. PCIT(E) stated that these provisions were applicable in respect

Shree Swaminarayan Mandir, Amreli vs. The CIT(Exemption) Ahmedabad, Ahmedabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 887/RJT/2024[2023-24]Status: DisposedITAT Rajkot13 Oct 2025AY 2023-24

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.887/Rjt/2024 (िनधा"रण वष" / Assessment Year: (Na) (Physical Hearing) बनाम/ Shree Swaminarayan Mandir The Cit (Exemption), Amreli, Ahmedabad Vs. Pani Darvaja – Amreli, Gujarat-365601 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaets6992F (अपीलाथ"/Appellant) (""यथ" /Respondent) अपीलाथ" ओर से/ Appellant By Ms. Devina Patel, Ar ""यथ" क" ओर से/Respondent By Shri Sanjay Pnglia, Cit Dr सुनवाई क" तारीख/Date Of Hearing 25/09/2025 घोषणा क" तारीख /Date Of Pronouncement 13 /10/2025 आदेश / O R D E R Per Dr. Arjun Lal Saini, A.M Captioned Appeal Filed By The Assessee, Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Exemption), [In Short “The Ld. Cit(E)”], Ahmedabad Wherein Ld. Cit(E) Rejected Assessee’S Application Filed In Form No.10Ab U/S 12A(1)(Ac)(Iii) Of The Act & Also Rejected Provisional Registration Of The Assessee, As The Assessee Did Not Appear Before The Ld. Cit(E) & Did Not File Any Documentary Evidences To Enable Him To Satisfy About The Genuineness Of The Activities Of The Trust, Whether The Activity Of The Trust Or Institution Are In Consonance With The Objects Of The Trust.

Section 12ASection 12A(1)(ac)

assessee did not appear before the Ld. CIT(E) and did not file the documentary evidences before the Ld. CIT(E) for registration under Section 12A(1)(ac)(iii) of the Act. Since the assessee failed to submit requisite details and documents which were called

Hijaldiha Vivekananda Seva Samity, Hijaldiha vs. CIT(Exemptions), Kolkata

Appeal of the assessee is dismissed

ITA 1177/KOL/2025[----]Status: DisposedITAT Kolkata13 Oct 2025

Bench: 01.04.2021. Being An Old Registered Trust Assessee Has Filed Application For Registration U/S.

Section 124(1)(ac)Section 12ASection 12A(1)(ac)Section 2

that original registration granted to the assessee, which is valid upto AY 2026-27, was a regular registration being an old Trust enjoying registration under section 12A before inception of new regime. Therefore, we are satisfied that our order has been suffering with an apparent error. This application ... 12A(1)(ac)(ii) of the Income Tax Act, 1961. This cancellation was erroneously made on the premise of the Appellant already holding registration under section 12A(1)(ac)(i) (via application Form No. 10A) of the Income Tax Act, 1961 Such an action is contrary to the legislative intent

Shri Ramkumar Meghraj Tekariwal Baraganwala Charitable Trust, Mumbai vs. CIT(Exemption), Mumbai

In the result the appeal filed by the assessee stands allowed for statistical purposes

ITA 4808/MUM/2025[N.A]Status: DisposedITAT Mumbai13 Oct 2025

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

Section 12ASection 5Section 80GSection 80G(5)Section 80G(5)(iii)

light of record placed before us. 4. It is noted that the assessee is admittedly an old trust having a valid registration under section 12A and 80G. 4.1 It is noted that while filing Form for final registration in Form 10AB has inadvertently mentioned the wrong section as sub-clause

Navras School of Performing Arts, Patna vs. CIT(E)Patna, Patna

In the result, the appeal of the assessee is dismissed

ITA 194/PAT/2025[2023-24]Status: DisposedITAT Patna10 Oct 2025AY 2023-24

Bench: Ms. Madhumita Roy & Shri Rakesh Mishra

Section 12A

IN THE INCOME TAX APPELLATE TRIBUNAL BENCH-PATNA VIRTUAL HEARING AT KOLKATA Before Ms. Madhumita Roy, Judicial Member and Shri

Haryana Building and Other Construction Workers Welfare Board, Panchkula vs. DCIT, Exemption, Chandigarh

In the result, this appeal of the Assessee stands dismissed

ITA 337/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh10 Oct 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 237/Chd/2020 निर्धारण वर्ष / Assessment Year : 2014-15 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29- 30, Sector 4, Panchkula, Haryana The Dcit, बनाम Circle 2, Vs. Exemption, Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं./ Ita Nos.337 To 339/Chd/2023 निर्धारण वर्ष / Assessment Years : 2016-17, 2017-18 & 2018-19 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29- 30, Sector 4, Panchkula, Haryana The Dcit बनाम Exemption, Vs. Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं./ Ita No. 63/Chd/2021 निर्धारण वर्ष / Assessment Year : 2015-16 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29-30, Sector 4, Panchkula, Haryana The Dcit बनाम Exemptions, Vs. Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent ( Physical Hearing ) निर्धारिती की ओर से/Assessee By : Sh. Nikhil Goyal, Advocate, Sh. Ashok Goyal, Ca & Sh. Sifatfreet Singh, Ca राजस्व की ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई की तारीख/Date Of Hearing 08.12.2025 उदघोषणा की तारीख/Date Of Pronouncement 10.12.2025 आदेश/Order Per Bench: The Captioned Appeals Preferred By The Assessee Are Directed Against The Separate Orders Of The Ld. Commissioner Of Income- Tax (Appeals) For Different Assessment Years, As Per The Details Given Below: S.No.

For Appellant: Sh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

आयकर अपीलीय अधिकरण, चण्डीगढ़ न्यायपीठ, चण्डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI LALIET KUMAR

Gaia Conservation Foundation, Mumbai vs. CIT (Exemption), Mumbai

The appeal of the assessee is allowed for statistical purposes

ITA 4540/MUM/2025[2025-26]Status: DisposedITAT Mumbai10 Oct 2025AY 2025-26

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth - AdvocateFor Respondent: Shri Arun Kanti Datta, CIT-DR

Section 12ASection 8Section 80GSection 80G(5)

when the assessee has otherwise complied by filing the required details. The consistent view expressed by various judicial forums has been that the registration under section 12A or under section 80G should not be rejected on the only ground of mentioning of wrong section which is a rectifiable mistake

Dy. Commissioner of Income Tax, Bkc, Mumbai vs. Tata Social Welfare Trust, Mumbai

In the result, appeals are dismissed

ITA 3442/MUM/2025[2017-18]Status: DisposedITAT Mumbai10 Oct 2025AY 2017-18

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Appellant: Shri P.J. Pardiwala a/w ShriFor Respondent: Shri Ritesh Mishra, CIT DR

Section 10Section 10(34)Section 11Section 13(1)(d)Section 143(3)Section 147Section 164(2)Section 3Section 7

assessee, particularly when it pertained to the registration obtained in a period prior to the insertion of section 12AA. The present cancellation of registration under section 12A must, therefore, be held to be effective from 20th March 2015. To this limited extent, we uphold the plea of the assessee ... 2486/Mum/2025 ITA 2475, 3441 and 3442/Mum/2025 Tata Social Welfare Trust, requiring the assessee to show cause as to why registration under section 12A not be cancelled, and the assessee formally acquiesced to the said notice 10.03.2015, i.e on 20th March 2015. 9. As no distinguishing decision has been brought