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TMI Blog2025 (3) TMI 227X X X X Extracts X X X X X X X X Extracts X X X X ..... Ms Vibha Gulabani,. PC:-(PER JITENDRA JAIN, J.) 1. Heard learned Counsel for the parties. 2. This Appeal is filed by the Appellant-Assessee challenging the order of the Tribunal passed on 4 January 2017. 3. The substantial questions of law proposed by the Appellant-Assessee is, by consent of the parties reframed as under:- Whether the Tribunal was justified in confirming the penalty under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 11 on the premise that the application made for registration in Form 10A would be granted from the day when the Trust came into existence. However, the CIT exemption issued Section 12A certificate on 31 March 2009 and in the said certificate, it was mentioned that registration is effective from 1 April 2008 i.e. Assessment year 2009-2010. 7. Since the registration certificate under 12A was give ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e. The CIT (A) relied upon the decision of the Hon'ble Supreme Court in the case of CIT Vs. Reliance Petroproducts [2010] 3 Taxmann.com 47. The Revenue challenged the order of the CIT (A) deleting the penalty by filing an Appeal to the Tribunal and the Tribunal vide its order dated 4 January 2017, allowed the Appeal of the Revenue and confirmed the penalty. 9. We have heard learned Counsel for th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it applicable from Assessment year 2009-2010 only cannot be attributed to the Appellant-Assessee. There is no reason given as to why the registration could not have been granted with effect from the date when the firm came into existence. 12. In any case, the Appellant-Assessee is a Charitable Trust and was under a bona fide belief that the registration certificate would be granted from the date ..... X X X X Extracts X X X X X X X X Extracts X X X X
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