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2023 (10) TMI 848

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..... le and a matter of serious concern as to how two sets of audit reports, which, as observed by the CIT(Exemption), revealed a glaring mismatch in the total income and expenditure, had been filed by the assessee society in the course of the proceedings before him. We are of a strong conviction that as the genuineness of the activities of the assessee society has not been substantiated, no infirmity emerges from the order of the CIT(Exemption), Bhopal, who had rightly declined its application for grant of registration u/s. 12AB - CIT(Exemption) rightly declined the application filed by the assessee society for grant of registration u/s. 12AB - Decided against assessee. - Shri Ravish Sood, Judicial Member And Shri Arun Khodpia, Accountan .....

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..... , stated to be engaged in the activities of taking care of poor children's fees/stationary/school dress, providing sports equipment and prize money for competitions, running smart classes training, organizing free eye camps/dental checkup camps/health camps, carrying out plantation, renovating toilets, providing sanitary napkins, and organizing debate competitions etc., had applied in Form 10AB for registration u/s. 12AB of the Act with the CIT(Exemption), Bhopal. 3. Considering the fact that in the income and expenditure account submitted by the assessee society for F.Y 2019-20 to F.Y 2021-22, no expenditure was incurred in relation to the aforesaid activities, which were claimed to have been carried out by the assessee society, .....

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..... was not running any schools or educational institutions independently. Referring to the aforesaid serious discrepancies emerging from the books of account and audit reports of the assessee society, the CIT(Exemption) observed that the assessee society had never maintained the same properly. Observing that the assessee society was maintaining two types of audit reports for each year, the CIT(Appeals) was of the view that on the said count itself, it was not liable for registration u/s. 12AB of the Act. Accordingly, the CIT(Exemption) vide his order dated 22.12.2022 declined the application of the assessee society for a grant of registration u/s. 12AB of the Act. 5. Aggrieved, the assessee society has assailed the order passed by the CIT(E .....

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..... he record that the assessee society on being queried about the expenses incurred in relation to the activities which were claimed to have been carried out by it, had come forth with two audit reports of the assessee society for F.Y 2019-20 to F.Y 2021-22. It is absolutely incomprehensible and a matter of serious concern as to how two sets of audit reports, which, as observed by the CIT(Exemption), revealed a glaring mismatch in the total income and expenditure, had been filed by the assessee society in the course of the proceedings before him. 9. Be that as it may, we are of a strong conviction that as the genuineness of the activities of the assessee society has not been substantiated, no infirmity emerges from the order of the CIT(Exem .....

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