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

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y.-Na Athitheyam Nyas, Vs. Commissioner Of Income-Tax C/O Kalyan Sewa Ashram, Amraknatk (Exemption), Bhopal Dt-Anuppur, M.P. 484886 Pan:Aakta1783A (Appellant) (Respondent) Assessee By: Sh. P.C. Bardia & Sh. Rahul Bardia, C.As. Revenue By: Sh. Shravan Kumar Meena, Cit Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 30.09.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Orders Of The Ld. Cit (Exemption), Bhopal Wherein The Ld. Cit (Exemption) Has Rejected The Application Filed By The Assessee In Form No. 10Ab For Registration Under Section 12B Of The Income Tax Act. The Grounds Of Appeal Are As Under:- “1. That Without Considering The Reply E Filed/Mailed Dated 20.03.2024, The Cit(Exemp) Erred In Cancelling The Provisional Registration Granted On 28.11.2023 & Rejecting 10Ab Form For Permanent Registration Vide Order Dated 21.03.2025 Due To Non-Submission Of Reply To Notice Dated 13.03.2025 Up To 18.03.2025 Alleging: - 1. Failure To Explain The Reason For Delay In Filling Form 10Ab Without Considering Fresh/Corrected 10Ab Form Filed On 18.03.2025 U/S 12A(Ac)(1)(Vi)(B) Under New Law. 2. Not Justifying Dissolution Clause No. 23 Allowing Use Of Funds By The Settlors/Trustees- Without Referring Clause No. 19,20, 21 & 22 Of The Trust Deed. 3. The Trust Is Irrevocable- Not Correct-Without Referring Irrevocable Clause No. 19 Of The Trust Deed.

B) under new law. 2. Not justifying dissolution clause No. 23 allowing use of funds by the Settlors/trustees- without referring clause No. 19,20, 21 and 22 of the trust deed. 3. The trust is irrevocable- not correct-without referring irrevocable clause No. 19 of the trust deed. 1 Athitheyam Nyas 4. The trust running hotel on commercial basis