Date of Hearing 02/06/2025 Date of Pronouncement 20/08/2025 (आदेश)/ORDER PER SMT. ANNAPURNA GUPTA, AM:

The present appeal has been filed by the assessee against the order of the Ld. Commissioner of Income Tax (Exemption), (hereinafter referred to as “CIT(E)”), Ahmedabad dated 29.12.2024, denying grant of final registration under section 12A of the Income Tax Act, 1961 (hereinafter referred to as the “Act”).

2. The orders of the authorities below reveal that the assessee had been granted provisional registration in Form 10AC on 25.10.2022 from A.Y. 2023-24 to A.Y. 2025-26. The assessee was an old trust incorporated on 14^th October, 1996 registered with the Assistant Charity Commissioner, Surat. Subsequent to grant of provisional registration, the assessee filed an application in Form 10AB seeking final registration u/s.12A of the Act. However, the same was rejected by the Ld. CIT(E) noting that no expenditure had been incurred by the assessee trust on its objects and as a consequence, he concluded that the assessee trust was not carrying out any activities towards its charitable objects. The Ld. CIT(E) accordingly held that the genuineness of the activities of the assessee trust cou