9911796707
TMI Blog2023 (10) TMI 848X X X X Extracts X X X X X X X X Extracts X X X X ..... iety has assailed the order of the CIT(Exemption), Bhopal, on the following grounds of appeal before us: "1) That learned CIT(Exemption) erred in rejecting application for grant of registration u/s. 12A(1)(ac)(iii) of the Income-tax Act, 1961 of the society on the basis of grounds those are not required to be fulfilled as per law while disposing of said application of the society, without properly appreciating the materials furnished before her to prove that society is genuine and is engaged in charitable activities and without considering the facts and circumstances of the ease properly and judicially. 2) That learned CIT(Exemption) erred in rejecting application for grant of registration u/s. 12A(1)(ac)(iii) of the Income-tax Act, 196 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tted that certain clerical errors had crept in while preparing the audit reports for the aforesaid years, i.e., F.Y. 2019-20 to F.Y 2021-22, as a result whereof, the aforesaid expenses incurred in relation to the activities of the assessee society had remained omitted to be disclosed. Interestingly, the assessee society furnished another copy of the audit reports for all the aforementioned three years, i.e., FY. 2019-20 to FY 2021-22, after removing the so called errors in the earlier reports. 4. The CIT(Exemption) observed that both the old and new audit reports for the aforementioned financial years, i.e., FY. 2019-20 to F.Y 2021-22 were completely different. Analyzing the old vis-à-vis new audit reports for all three years, the C ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he bench as to on what basis the assessee society had filed a twin set of audit reports before the CIT(Exemption), Bhopal, the Ld. Authorized Representative (for short, "AR") failed to come forth with any plausible explanation as regards the same. 7. Before proceeding any further, we deem it fit to cull out the provisions of Section 12AB of the Act, which reads as under (relevant extract) : "12AB. (1) The Principal Commissioner or Commissioner......... (a) where the application is made .......... (b) where the application is made under sub-clause (ii) or sub-clause (iii) or sub-clause (iv) or sub-clause (v) of the said clause,- (i) call for ............ (ii) after satisfying himself............ (A) pass an order.............. ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
