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IN THE INCOME TAX APPELLATE TRIBUNAL

AMRITSAR BENCH: AMRITSAR.

BEFORE SH. MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER

AND

SH. UDAYAN DAS GUPTA, JUDICIAL MEMBER

(Physical Hearing)

I.T.A. No. 115 & 116/Asr/2025

Assessment Year.: 2022-23

C-Dot Forum, 644 Phase-1, Vs. CIT (Exemptions)

Model Town Bathinda. Chandigarh.

[PAN: AAEAC3681J]

(Appellant)

(Respondent)

Appellant by Sh. Rishabh Marwaha, CA

Respondent by Sh. Sunil Gautam, CIT. DR

Date of Hearing 17.12.2025

Date of Pronouncement 29.01.2026

ORDER

Per: Udayan Das Gupta, J.M.:

This appeal is filed by the assessee against the order of the Ld. CIT (E)

Chandigarh, dated 12^th December, 2024, rejecting the application for registration u/s

12A(i)(ac)(iii), filed by the assessee in form 10AB on 30^th September, 2023.

ITA No.115/Asr/2025

2. The grounds of appeal taken by the assessee in form 36 are as follows:

I.T.A. No. 115 & 116/Asr/2025 2

Assessment Year.: 2022-23

1. The Commissioner of Income Tax (Exemptions) Chandigarh,

has eared in Law and on facts, in rejecting the application in

form 10AB U/S 12AB of the Income Tax Act, 1961, on non-

satisfaction of genuineness of the activities of the assessee

society, only based on her presumptions in this regard.

2. The CIT (Exemption) has eared in law, in rejecting the

application, having not considered, the tangible material

submitted during the proceeding u/s 12AB of Income Tax Act,

1961.

3. Without prejudice to the above, the CIT has also erred in not

considering the fact that the conference expenses as incurred by

the appellant the spread of knowledge of best practices and new

medicines/ treatments among the doctors includes the public at

large, who are affected by the services of such doctors and as

such charitable in nature as 'advancement of an object of general

public utility'.

4. That the Worthy CIT(A) has erred in not considering the fact

that in the absence of the above activities made, in addition to the

free distribution of medicines to the poor and free medical camps

for the public, the object and purpose of the Medical Relief, Relief

to Poor and Advancement of an object of General Public Utility

to the public at large i.e. the objects of the assessee society,

cannot be met effectively.

I.T.A. No. 115 & 116/Asr/2025 3

Assessment Year.: 2022-23

5. That CIT has also erred in rejecting the application for

registration of the trust us 12AB only on the basis of volume of

the, only alleged, charitable activity undertaken by the assessee

society, being the distribution of the free medicines for the

diabetes in children at the medical camp.

6. That CIT has also erred in rejecting the application for

registration of the trust us 12AB on the basis of the donations

being received by the assessee society from the pharma

companies, which have been used for the objects of the trust,

without pointing out any single instance of benefit being passed

on to a single person or interested person us 13(3) of the Act.

7. That CIT has also erred in rejecting the application for

registration of the assessee society us 12AB based on conjectures

and surmises and against the facts and circumstances of the case.

8. That the appellant craves leave to add or amend the grounds

of appeal before the appeal is finally heard or disposed off.”

3. This is the second round of appeal, whereby the application for

registration was originally rejected by the Ld. CIT (E) Chandigarh, on 20^th

March, 2024, and the matter brought in appeal before the tribunal, was

remanded back to the Ld. CIT (E) vide this tribunal order dated 9^th July, 2024,

for re - consideration of the same, in absence of proper opportunity being

provided before rejection, which violated the principles of natural justice.

I.T.A. No. 115 & 116/Asr/2025 4

Assessment Year.: 2022-23

4. In course of fresh hearing various queries were raised by the Ld. CIT (E),

in response to which submissions along with documentary evidences

(photographs and others) and financial of income and expenditure and bank

statements for the year ending March 2022 to March 2