9911796707
TMI Blog2025 (3) TMI 81X X X X Extracts X X X X X X X X Extracts X X X X ..... pproval under Section 80G(5)(iii) of the Income Tax Act, 1961 [hereinafter referred to as "the Act"]. Since both the appeals involve similar facts and legal issues, they are being disposed of by this consolidated order. Facts of the Case: 2. The assessee, Apna Charitable Trust, is a public charitable trust engaged in providing medical treatment and concessional medicines through its hospital and pharmacy units. The trust was granted provisional registration under Section 12A(1) of the Act from 07.04.2022 to A.Y. 2024-25 and, subsequently, applied for renewal of registration under Section 12A(1)(ac)(iii) of the Act through Form 10AB. Additionally, the assessee also applied for approval under Section 80G(5)(iii) of the Act by filing anothe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 09.2024 rejected the application under Section 80G(5)(iii) of the Act on similar grounds, stating that the assessee had failed to satisfy the genuineness of activities, and the conditions prescribed under Section 80G(5)(i) to (v) of the Act. 4. Aggrieved by these rejections, the assessee has filed the present appeals before us, contending that the CIT(E) has completely ignored the submissions filed on 21.08.2024, leading to an erroneous rejection order. The assessee has raised the following grounds in both the appeals:- In ITA No. 1899/Ahd/2024 "1. CIT(Exemption) Ahmedabad erred in law and on facts in renewal application for approval under section 12A(1)(ac) (iii) of The Income Tax Act, 1961 on ground of non-compliance 2. The appell ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he application for renewal of Exemption U/s 80G(5)(iii) of the IT Act on ground of non-compliance vide order dt. 03.09.2024" 5 During the course of hearing before us, the Authorized Representative (AR) submitted that in reply to notice relating to renewal under Section 12A(1)(ac)(iii) of the Act, the assessee had fully complied with the notice dated 06.08.2024 by submitting all required documents on 21.08.2024. In case of approval under Section 80G(5) (iii) of the Act also the AR submitted that a detailed reply along with all supporting documents was filed on 21.08.2024, in response to the notice dated 09.08.2024. 5.1. The AR further stated that the CIT(E) ignored this submission and passed orders citing non-compliance, despite the fact ..... X X X X Extracts X X X X X X X X Extracts X X X X
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