Mahaveer (I) Foundation Trust. v. CIT (2025) 213 ITD 21 (Pune) (Trib.)

S. 12A: Registration –Trust or institution-Additional evidence filed-The matter was remanded back to the Commissioner (E) with a direction to grant an opportunity to the assessee to substantiate its case by filing requisite details/explanation to his satisfaction and adjudicate the issue afresh on merits as per fact and law.[S.11, 12AB]

Commissioner (E) rejected the application for registration filed by assessee-trust on the ground that assessee had failed to submit documentary evidence in support of charitable activities carried out by assessee. On appeal, the Tribunal held that since additional evidence filed by assessee went to the root of the matter, the matter was remanded back to the Commissioner (E) with a direction to grant an opportunity to assessee to substantiate its case by filing requisite details/explanation to his satisfaction and adjudicate the issue afresh on merits as per fact and law.

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