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2025 (4) TMI 1425

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..... einafter referred to as the "impugned order". Registry informed that there is delay of 4 days in filing the appeal. Delay of 4 days condoned for which assessee has shown sufficient cause. Appeal admitted and taken up for hearing. 2. FACTUAL MATRIX 2.1 The appellant is a Society, registered under the Madhya Pradesh Societies Registration Act, 1973 vide certificate of Regn. No. 03/27/01/21903/19 Dated 30/07/2019 and was provisionally registered under Section 12A having provisional Registration No. AAYTS3286QE20211 from AY 2022-23 to AY 2024-25 through order of CIT exemption dated 05/04/2022. 2.2 The objective of the Society is to run educational and social and spiritual activities and also to construct and operate nursery, primary, middl .....

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..... ating that - - address and mobile number of the Donor has not been submitted. - Complete address and direction from the donor or any supporting documents of Corpus not Submitted. - Proper details of subscriptions shown in Income & Expenditure accounts not submitted. 2.8 The application of the assessee in Form 10AB for grant of registration u/s 12AB is rejected and the provisional registration/approval u/s 12AB in Form 10 AC vide URN No. AAYTS3286QE20211 dated 05.04.2022 is also cancelled saying non-compliance of required documents/information. 2.9 That the aforesaid order bears Number ITBA/EXM/F/EXM45/2023-24/1061949534(1) and same is dated 04.03.2024 (the impugned order) supra. 2.10 That the assessee being aggrieved by the impugne .....

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..... trongly oppose the contention of the Ld. AR and finally left it to this Tribunal to take appropriate call on this issue in accordance with law. In rejoinder Ld. AR submitted that they indeed regret non compliance on part of the assessee but asserted that in Audit Report donation amount could be seen as having been received through normal banking channels. The assessee has now compiled the details and that they are ready to submit the same. 4. Observations, findings & conclusions. 4.1 We now have to decide the legality, validity and proprietary of the "Impugned Order" basis records of the case and contentions canvassed before us. 4.2 We have minutely perused records of the case and have heard the rival submissions. 4.3 We are of the cons .....

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