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2021 (8) TMI 209 - AT - Income TaxExemption u/s 11 - registration u/s. 12AA denied - objects of religious-cum-charitable trust - voluntarily contributions/donations received and credited to the corpus accounts during the financial years 2017-18 and 2018-19 were not offered to tax and paid the taxes thereon - HELD THAT:- Grant of registration and assessment are two separate and distinct procedures prescribed under the Income Tax Act. The issues of assessment cannot be considered at the time of grant of registration. CIT (Exemption) had denied the grant of registration by taking into consideration that the corpus donations collected during the financial years 2017-18 and 2018-19 had escaped assessment to tax which clearly falls under the realm of the "assessment". In view of the settled position of law discussed above, we are of the considered opinion that the grounds on which the ld. CIT (Exemption) had rejected the grant of registration are untenable in law. Accordingly, we direct the ld. CIT (Exemption) to grant the registration u/s. 12AA of the Act. - Decided in favour of assessee.
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