Trust's Section 12AB Registration Upheld: Procedural Fairness Prevails in Exemption Determination Under Section 11

ITAT addressed registration denial under Section 12AB, focusing on Trust's eligibility for exemption under Section 11. Jurisdictional HC judgment in CIT(E) vs. Jamiatul Banaat Tankaria established that Section 13 provisions apply during assessment, not registration. For Trusts created before 01-04-2021, registration eligibility precedes Section 13(1)(b) applicability. ITAT allowed assessee's appeal, directing CIT (Exemption) to grant final registration under Section 12AB after providing hearing opportunity, effectively reinstating Trust's registration status subject to subsequent assessment scrutiny. .....

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