TMI Blog2022 (9) TMI 1495X X X X Extracts X X X X X X X X Extracts X X X X ..... on u/s.12A filed by the appellant. The appellant deserves registration. 2. The Ld. CIT has erred in law and facts in rejecting the application made for registration u/s.12A on the irrelevant grounds. The appellant deserves registration. 3. The Ld. CIT has erred in law and facts in rejecting the application made for registration u/s.12A on the irrelevant considerations. The appellant deserves registration. 4. The Ld. CIT has erred in law in not appreciating that as per legal and statutory position, the appellant was deserving registration. The appellant deserves registration. 5. The Ld. CIT has erred in not granting registration without appreciating the factual and legal position that the appellant deserves registration from the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d that the following information amongst other Sr. No. 3 3. Please state whether jurisdiction over the case vest with CIT(E), Ahmadabad with details of ward/ circle where you are filling return of income. 4.1 Apparently it is humbly submitted that how this information called for is connected with the conclusion drawn by the Ld. CIT that he is not satisfied with the genuineness of the activities. Apparently it stand established that rejection of the application is based on irrelevant consideration. 4.2 Not only this the trust deed has already been submitted along with the application in spite of this Sr. No. 4 of his letter state whether trust contains religious, at Sr. No. 6 it is asked regarding object of the trust although it is fu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... come and expenditure account is already furnished. The rejection of 12A application will not approve. 27 SOT 423 Delhi ITAT. 5. Even if there is some suspicion regarding income as well as resources rejection was not approve by the Hon. P& H HIGH COURT 221 TAXMAN. 6. When refusal of registration without making any adverse comment of the genuine activity and the charitable nature of the object registration was directed to grant 174 TTJ 20 ITAT Jodhpur. 7. When charitable character was no where question without bringing any material on record that the activities of the assessee was not genuine registration was directed to be granted 156 ITD 117 Chandigarh 1TAT. 8. Now it is apparent from the order of rejection of application clearl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee at any point of time. But, since the assessee has not been given any opportunity of hearing for placing the documents called for by the CIT (Exemptions), we are condoning the delay and direct the CIT(Exemptions) to consider the application of the assessee filed under Section 12AA of the Act after taking cognisance of the details filed before the CIT(Exemptions). Needless to say the assessee be given opportunity of hearing by following the principles of natural justice. We further direct the assessee to co-operate with the proceedings and file the relevant details within the stipulated time given by the CIT(Exemptions) otherwise the CIT(Exemptions) can decide the case according to the law. 8. In the result, appeal filed by ..... X X X X Extracts X X X X X X X X Extracts X X X X
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