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2025 Supreme(Online)(ITAT) 5279

INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
NARENDRA PRASAD SINHA, ACJ, SANJAY GARG, J
Shree Rajnibhai Kanada Memorial Foundation – Appellant
Versus
Commissioner of Income Tax (Exemption) – Respondent


Advocates:
For the Appellants/Petitioners: Shri Mohit Balani, AR
For the Respondents: Shri Rignesh Das, CIT-DR

Table of Content
1. appellate background and procedural details. (Para 1 , 2)
2. grounds of appeal presented by the appellant. (Para 3)
3. respondent's reliance on initial decision. (Para 4)
4. court's analysis of trust activities and relevant legal standards. (Para 5)
5. judgment allowing the appeal for procedural reconsideration. (Para 6)

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of the Commissioner of Income Tax (Exemption), Ahmedabad (in short ‘the CIT(E)’) dated 29.08.2024 rejecting the application for grant of approval under Section 80G (5) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. The assessee has raised the following grounds in this appeal: -

1. Learned CIT(E) has erred in law and on the facts of the case in passing the impugned order, rejecting the registration u/s.80G of the Act.

2. Learned CIT(E) has erred in law and on the facts of the case in passing the order u/s.80G of the Act in gross violation of principle of natural justice.

3. Your Appellant reserves the right to add, alter, modify or delete any ground of appeal.”

3. Shri Mohit Balani, the Ld. AR of the assessee submitted that the assess

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