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TMI Blog2025 (1) TMI 971X X X X Extracts X X X X X X X X Extracts X X X X ..... jected the claim made by the assessee u/s.10(23C) only on technical issue, which is uncalled for CIT(A) has rightly considered all the aspects viz, registration u/s.12A and application of income for the charitable purposes while granting exemption u/s.11. We therefore find that the order passed by the CIT(A) is in conformity with the principles of natural justice. We therefore uphold the same and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he CPC vide its order u/s.143(1) processed the return rejecting the claim made by the assessee u/s.10(23C) of the Act at Rs. 4,85,92,788/-. Being aggrieved by the intimation order denying the said claim, the assessee filed the rectification application u/s.154 of the Act but the assessee failed to succeed on the ground that the assessee has not furnished the Audit report in Form No.10BB within the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appellant to the extent of Rs 4,85,92,788/- was rejected by the AO. The Appellant filed rectification petition u/s 154 but the petition was rejected by the AO vide order u/s 154 dated 30-03-2023. The AO rejected the claim by holding that the Appellant has given the details of registration u/s 10(23c)(vi) details of registration u/s 10(23c) (vi) and therefore the Appellant was required to submit th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Appellant trust. Denial of exemption would be unfair and against the principles of natural Justice and equity. In view of the above, the AO was not justified in denying the claim of exemption and the AO is hereby directed to allow the claim of exemption u/s.11 12 of the Act. These grounds are allowed. 4. Now the Revenue is in appeal before the Tribunal contending that filing of Audit Report in For ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he ld.CIT(A) has rightly considered all the aspects viz, registration u/s.12A and application of income for the charitable purposes while granting exemption u/s.11 of the Act. We therefore find that the order passed by the ld.CIT(A) is in conformity with the principles of natural justice. We therefore uphold the same and dismiss the grounds raised by the Revenue. 7. In the result, the appeal of th ..... X X X X Extracts X X X X X X X X Extracts X X X X
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