VIKEKANANDA FOUNDATION,KOLKATA vs. CIT(EXEMPTION), KOLKATA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. Nos. 449 & 464/Kol/2024 Vivekananda Foundation,……………..…..…Appellant 247, Deshapran Sasmal Road, Kolkata, Tollygunge, H.O. Kolkata, West Bengal, India, Pin-700033 [Pan:Aabtv2665D] -Vs.- Commissioner Of Income Tax (Exemption),Respondent Kolkata, Income Tax Department, 6Th Floor, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri P.K. Ray & R.C. Halder, Advocate, Appeared On Behalf Of The Assessee Shri S. Datta, Cit, D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 21, 2024 Date Of Pronouncing The Order: July 04, 2024 O R D E R

Trust, order dated 07.05.2024. In this judgment, ITAT has considered the Board Circular and propounded as to how ld. CIT(Exemption) ought to have dealt with these applications instead of dismissing them mechanically. The discussion made by the Tribunal reads as under:- “2. ITA No.321/Kol/2024 – The brief facts of the case are that the assessee was already registered/approved u/s 80G

VIVEKANANDA FOUNDATION,KOLKATA vs. CIT(EXEMPTION), KOLKATA

In the result, both the appeals of the assessee are allowed for statistical purposes

Bench: Shri Rajpal Yadav, Vice-(Kz) & Shri Rajesh Kumari.T.A. Nos. 449 & 464/Kol/2024 Vivekananda Foundation,……………..…..…Appellant 247, Deshapran Sasmal Road, Kolkata, Tollygunge, H.O. Kolkata, West Bengal, India, Pin-700033 [Pan:Aabtv2665D] -Vs.- Commissioner Of Income Tax (Exemption),Respondent Kolkata, Income Tax Department, 6Th Floor, 10B, Middleton Row, Kolkata-700071 Appearances By: Shri P.K. Ray & R.C. Halder, Advocate, Appeared On Behalf Of The Assessee Shri S. Datta, Cit, D.R. Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 21, 2024 Date Of Pronouncing The Order: July 04, 2024 O R D E R

Trust, order dated 07.05.2024. In this judgment, ITAT has considered the Board Circular and propounded as to how ld. CIT(Exemption) ought to have dealt with these applications instead of dismissing them mechanically. The discussion made by the Tribunal reads as under:- “2. ITA No.321/Kol/2024 – The brief facts of the case are that the assessee was already registered/approved u/s 80G

SUDAMA MAHABIR KEDIA CHARTABLE TRUST,CIT(EXEMPTION) vs. CIT(EXEMPTION), KOLKATA

The appeals of the assessees are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. Nos.80/Kol/2024 Sudama Mahabir Kedia Charitable Trust…................……………....Appellant Meleod House, 1St Floor, 3, Netaji Subhas Road, Kolkata-700001. [Pan: Aamts1725L] Vs. Cit(Exemption), Kolkata….……………............................…..…..... Respondent Appearances By: Shri Giridhar Dhelia, Advocate, Appeared On Behalf Of The Appellant. Shri Subhendu Datta, Cit-Dr, Appeared On Behalf Of The Respondent.

80G(5) This section applies to donations to any institution or fund referred to in sub-clause (iv) of clause (a) of sub-section (2), only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution

LIONS CLUB OF CALCUTTA,KOLKATA vs. CIT(EXEMPTION), KOLKATA

The appeals of the assessees are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Sanjay Awasthii.T.A. Nos.80/Kol/2024 Sudama Mahabir Kedia Charitable Trust…................……………....Appellant Meleod House, 1St Floor, 3, Netaji Subhas Road, Kolkata-700001. [Pan: Aamts1725L] Vs. Cit(Exemption), Kolkata….……………............................…..…..... Respondent Appearances By: Shri Giridhar Dhelia, Advocate, Appeared On Behalf Of The Appellant. Shri Subhendu Datta, Cit-Dr, Appeared On Behalf Of The Respondent.

80G(5) This section applies to donations to any institution or fund referred to in sub-clause (iv) of clause (a) of sub-section (2), only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution

SATYANARAYAN SOMANI FOUNDATION,KOLKATA vs. CIT(EXEMPTION), KOLKATA

The appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.321/Kol/2024 Baijnath Somani Charitable Trust…......................…...……………....Appellant 5A, Woodburn Park Road, 3Rd Floor, Woodburn Central, Kolkata – 700020. [Pan: Aaatb5408K] Vs. Cit(Exemption), Kolkata….……………............................…..…..... Respondent

80G(5) This section applies to donations to any institution or fund referred to in sub-clause (iv) of clause (a) of sub-section (2), only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution

BAIJNATHSOMANI CHARITABLE TRUST,KOLKATA vs. CITIEXEMPTION), KOLKATA

The appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. Nos.321/Kol/2024 Baijnath Somani Charitable Trust…......................…...……………....Appellant 5A, Woodburn Park Road, 3Rd Floor, Woodburn Central, Kolkata – 700020. [Pan: Aaatb5408K] Vs. Cit(Exemption), Kolkata….……………............................…..…..... Respondent

80G(5) This section applies to donations to any institution or fund referred to in sub-clause (iv) of clause (a) of sub-section (2), only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution

M/S JMS MINING PVT. LTD,KOLKATA vs. PCIT-2, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Shri P. M .Jagtap, Vice-(Kz) & Shri A. T. Varkey, Jm]

Section 80G(1)(ii) of the Act. Situation 4 : The company has contributed Rs.1 crore to Prime Minister's National Relief Fund and Rs. 1 crore to any other charitable trust registered u/s 80G(5

NITDAA FOUNDATION,KOLKATA vs. CIT(E), KOLKATA

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

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishranitdaa Foundation, Commissioner Of Income Fe 261, Sector-Iii, Salt Lake, Tax (Exemption), Kolkata, Vs West Bengal -700106 10B, Middleton Row, (Pan: Aadtn2308K) West Bengal - 700071 (Appellant) (Respondent)

80G(5)(vi) of the Act as under: “(5) This section applies to donations to any institution or fund referred to in sub- clause (iv) of clause (a) of sub-section (2), only if it is established in India for a charitable purpose and if it fulfils the following conditions, namely:- (i) where the institution or fund derives any income

RAJBALHAT CULTURAL CIRCLE,KOLKATA vs. CIT(E), KOLKATA

The appeals of the assessee are treated as allowed for statistical purposes

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. Nos.25 & 26/Kol/2024 Rajbalhat Cultural Circle.……..…………............…...……………....Appellant At & Post Rajbalhat, District-Hooghly, Pin-712408. [Pan: Aabar5785R] Vs. Cit(Exemptions), Kolkata……...............................................…..…..... Respondent Appearances By: Shri P. K. Ray, Ar, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 12, 2024 Date Of Pronouncing The Order : May 13, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Dated 30.11.2023 & 20.12.2023 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Respectively. Ita No.25/Kol/2024 Is Against The Rejection Of Application For Registration U/S 12Aa(1)(Ac)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) & Ita No.26/Kol/2024 Is Against The Rejection Of The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Act. 2. Ita No.25/Kol/2024 - The Ld. Cit(Exemptions) Has Rejected The Application Holding The Same To Be Prima Facie Not Maintainable Being Premature. The Ld. Cit(Exemptions) Observed That The Assessee Earlier

trust to do so. In view of this, the impugned order of the ld. CIT(Exemptions) is set aside and the matter is restored to the ld. CIT(Exemptions) to consider the application of the assessee for final registration and grant the same if the same is otherwise so admissible to the assessee. 5. ITA No.26/Kol/2024 - The brief facts

MALLARPUR NAISUVA,BIRBHUM vs. CIT(E), KOLKATA. , KOLKATA

The appeal of the assessee is allowed accordingly and the ld

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. Nos.164&165/Kol/2024 Mallarpur Naisuva……………..…….…................…...……………....Appellant Mallarpur, Birbhum, W.B-731216. [Pan: Aabtm6211E] Vs. Cit(Exemptions), Kolkata.....…..........................................…..…..... Respondent Appearances By: Shri P. K. Ray, Ar & Daud Ahmed Buksh, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : April 09, 2024 Date Of Pronouncing The Order : April 23, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Captioned Appeals Have Been Preferred By The Assessee Against The Separate Orders Both Dated 09.01.2024 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’]. Ita No.164/Kol/2024 Is Against The Rejection Of Application For Registration U/S 12Aa(1)(Ac)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) & Ita No.165/Kol/2024 Is Against The Rejection Of The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Act. 2. Ita No.164/Kol/2024 - The Ld. Cit(Exemptions) Has Rejected The Application Holding The Same To Be Prima Facie Not Maintainable Being Premature. The Ld. Cit(Exemptions) Observed That The Assessee Earlier

trust to do so. In view of this, the impugned order of the ld. CIT(Exemptions) is set aside and the matter is restored to the ld. CIT(Exemptions) to consider the application of the assessee for final registration and grant the same if the same is otherwise so admissible to the assessee. 5. ITA No.165/Kol/2024 - The brief facts

RABINDRA BHARATI SOCIETY,KOLKATA vs. CIT(EXEMPTION), KOLKATA

The appeal of the assessee is allowed accordingly and the ld

Bench: Shri Sanjay Garg & Shri Rakesh Mishrai.T.A. No.278/Kol/2024 Rabindra Bharati Society……..………....................…...……………....Appellant At 5 Dwarka Nath Tagore Lane, Post Office Jorasanko, District Kolkata, Pin 700007, West Bengal [Pan: Aabtr7964H] Vs. Cit(Exemptions, Kolkata.…….……………............................…..…..... Respondent Appearances By: Shri P. K. Ray & R.C Halder, Advocate, Appeared On Behalf Of The Assessee. Shri Rakesh Kumar Das, Cit-Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : June 06, 2024 Date Of Pronouncing The Order : June 13, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 22.12.2023 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Already Registered/Approved U/S 80G(5) Of The Act As A Charitable Institution Since 06.04.2022. However, An Amendment Was Brought Into The Relevant Provisions Of Section 80G Of The Act Vide Taxation & Other Laws (Relaxation & Amendment Of Certain Provisions) Act, 2020 (Hereinafter Referred To As ‘Amendment Act Of 2020’) With Effect From 01.04.2021 Whereby, An Institution, Which Has Already Been Approved

charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner

ANUDIP FOUNDATION FOR SOCIAL WELFARE,KOLKATA vs. CIT(EXEMP), KOLKATA, KOLKATA

The appeal of the assessee is allowed accordingly and the ld

Bench: Shri Sanjay Garg & Girish Agrawali.T.A No. 1341/Kol/2023 Assessment Year: N/A Anudip Foundation For Social Welfare…………………........................……Appellant Cimsys Towers Plot-Y13, Block-Ep Salt Lake City Sector-V Kolkata - 700091 [Pan: Aagca3551K] Vs. Cit(Exemption), Kolkata......................…................…........……...…..…..Respondent Appearances By: Shri Giridhar Dhelia, A/R, Appeared On Behalf Of The Appellant. Shri S. Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 4Th, 2024 Date Of Pronouncing The Order : March 11Th , 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 22.11.2023 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Already Registered/Approved U/S 80G(5) Of The Act As A Charitable Institution Since 2008. However, An Amendment Was Brought Into The Relevant Provisions Of Section 80G Of The Act Vide Taxation & Other Laws

charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner

IAC PATRONS FOUNDATION,KOLKATA vs. CIT(EXEMPTION), KOLKATA

In the result, the appeal of the assessee is treated as allowed for 5

Bench: Shri Sanjay Garg & Rajesh Kumari.T.A No.320/Kol/2024 Assessment Year: N/A Iac Patrons Foundation……………………………… ........................……Appellant 5A, Woodburn Park Road, 3Rd Floor, Woodburn Central, Kolkata – 700020. [Pan: Aafci1833D] Vs. Cit(Exemption), Kolkata......................…................…........……...…..…..Respondent Appearances By: Shri Arvind Agarwal, Advocate, Appeared On Behalf Of The Appellant. Shri S. Datta, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 28, 2024 Date Of Pronouncing The Order : March 07, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 11.02.2024 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Already Registered/Approved U/S 80G(5) Of The Act As A Charitable Institution Since 2021. However, An Amendment Was Brought Into The Relevant Provisions Of Section 80G Of The Act Vide Taxation & Other Laws

charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner

DIVINE LIFE FOUNDATION,SILIGURI vs. CIT(E), KOLKATA. , KOLKATA

In the result, the appeal of the assessee is treated as allowed for 8

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.1252/Kol/2023 Assessment Year : N/A Divine Life Foundation……………………............…...……………....Appellant Ground Floor, Nani Gopal Mansion, Milanpally, Siliguri-734005. [Pan: Aactd2194E] Vs. Cit, Circle-10(1), Kolkata…….............................................…..…..... Respondent Appearances By: Shri Giridhari Dhelia, Ar, Appeared On Behalf Of The Appellant. Shri Rakesh Kumar Das, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 24, 2024 Date Of Pronouncing The Order : February 29, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.09.2023 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Already Registered/Approved U/S 80G(5) Of The Act As A Charitable Institution Since 2021. However, An Amendment Was Brought Into The Relevant Provisions Of Section 80G Of The Act Vide Taxation & Other Laws (Relaxation & Amendment Of Certain Provisions) Act, 2020 (Hereinafter Referred To As ‘Amendment Act Of 2020’) With Effect From 01.04.2021 Whereby, An

charitable purpose and if it fulfils the following conditions, namely:- [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application in the prescribed form and manner

TOMORROW'S FOUNDATION,KOLKATAL vs. CIT(EXEMPTION), KOLKATA

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

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A. No.367/Kol/2024 Tomorrow’S Foundation…………….…................…...….…………....Appellant 417, Hossenpur, Kmc Ward No.108, West Bengal – 700107. [Pan:Aaatt4262B] Vs. Cit(Exemption), Kolkata…...…..........................................…..…..... Respondent Appearances By: Shri C. Roy, Ca, Appeared On Behalf Of The Appellant. Shri Abhijit Kundu, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 27, 2024 Date Of Pronouncing The Order : February 27, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 11.02.2024 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Brief Facts Of The Case Are That The Assessee Was Already Registered/Approved U/S 80G(5) Of The Act As A Charitable Institution Since 1999. However, An Amendment Was Brought Into The Relevant Provisions Of Section 80G Of The Act Vide Taxation & Other Laws (Relaxation & Amendment Of Certain Provisions) Act, 2020 (Hereinafter Referred To As ‘Amendment Act Of 2020’) With Effect From 01.04.2021 Whereby, An Institution, Which Has Already Been Approved Before The Aforesaid

charitable purpose and if it fulfils the following conditions, namely:- I.T.A. No.367/Kol/2024 Tomorrow’s Foundation [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application

SETH MAHAVEER KUMAR SUSHILA DEVI JAIN CHARITABLE TRUST,KOLKATA vs. CIT(EXEMPTION), , KOLKATA

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

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Trust “3. We have heard the rival submissions and gone through the record. Before proceeding further, it will be relevant to reproduce here the relevant provisions of section 80G(5) of the Act: “80G(5) This section applies to donations to any institution or fund referred to in sub- clause (iv) of clause (a) of sub-section (2), only

SILIGURI SALASAR BALAJEE SEWA TRUST,SILIGURI vs. C.I.T., (EXEMPTION), KOLKATA

In the result, the appeal of the assessee is treated as allowed for\nstatistical purposes

trust had\nalready commenced in FY 2022-23. We have gone through the order\npassed by the ITAT, Kolkata as reliance made by the Ld. A.R and the\nrelevant portion of the order which is as under:\n“3. The issue is squarely covered by the decision of the Coordinate Kolkata\nBench of the Tribunal in the case of “Tomorrow

PRANAB MICRO SERVICES FEDERATION ,NADIA vs. CIT(EXEMPTION), KOLKATA. , KOLKATA

In the result, the appeal of the assessee is treated as allowed for 5

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.438/Kol/2024 Assessment Year: N/A Pranab Micro Services Federation,………………………..................……Appellant C/O. Paresh Saha, 30, Manipur Road, Nabadwip, Nadia-741302, West Bengal [Pan: Aakcp9808J] Vs. Cit(Exemption), Kolkata......................…................…........……...…..…..Respondent 10B, Middleton Row, Kolkata-700071 Appearances By: Shri Manoj Kataruka, A.R., Appeared On Behalf Of The Appellant. Shri P.P. Barman, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : March 08, 2024 Date Of Pronouncing The Order : March 11, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 26.02.2024 Of The Commissioner Of Income Tax (Exemption), Kolkata [Hereinafter Referred To As ‘Cit(Exemption)’] Rejecting The Application Of The Assessee For Final Approval As Per The Provisions Of Section 80G(5)(Iii) Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Case Are That The Assessee Has Already Been Registered As A Charitable Institution Under Section 12Aa Of The Income Tax Act. The Assessee Thereafter Applied For Provisional Approval Under Clause (Iv) To First Proviso To Section 80G(5) Of The Act. The Assessee Was Granted Provisional Approval U/S Clause (Iv) To First Proviso To Section

charitable purpose and if it fulfils the following conditions, namely:- I.T.A No.438/Kol/2024 Pranab Micro Services Federation [(vi) in relation to donations made after the 31st day of March, 1992, the institution or fund is for the time being [approved by the Principal Commissioner or Commissioner;] Provided that the institution or fund referred to in clause (vi) shall make an application