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3. The Ld. Counsel for the assessee referring to the order of rejection dated 10.03.2025 of the Ld. CIT(E), stated that registration was denied to the assessee u/s.12A on the ground that certain details were not furnished by the assessee, trust is not irrevocable and financial statement for the F.Y.2022-23 is unsigned and unaudited. The Ld. Counsel for the assessee referring to page-18 of the paper book submitted that in the event of dissolution of Trust, the assets of the trust shall be utilized for the fulfillment of the acts, aims and objectives of the trust up to finish or will transfer the rest of assets/fund to an organization working for the similar aims and objectives.

Page | 4 The true copy of this reply-dated 04.03.2025 is enclosed herewith as Annexure-"E"

08. Despite the same, the Ld. CIT(E) rejected the application filed by the appellant seeking registration on the ground that some discrepancies are noted in the documents filed by the appellant which are

a) the trust is not irrevocable and

b) financial statement for FY 2022-23 are unsigned and un- audited Ld. CIT(E) also cancelled the provisional registration granted vide order-dated 04.10.2022 having unique registration no. ABETS8469GE20221 issued for the period from AY 2023-24 to AY 2025-26.

Page | 7 While passing the order, Ld. CIT(E) has not commended upon the objects as well as genuineness of the activities of the foundation, meaning thereby that he was satisfied with the objects as well as genuineness of activities of the foundation.

04. The only ground raised by Ld. CIT(E) for rejecting the application is that the trust is not irrevocable and the financial statement for FY 2022-23 is unsigned and un- audited.

In so far as irrevocability of the trust is concerned, CIT(E), during the proceeding itself, could have pointed out to the appellant such discrepancy so as to include the said clause in the Trust Deed like any other disclosure or certificate on undertaking required by him.