IN THE INCOME TAX APPELLATE TRIBUNAL SURAT BENCH, SURAT (HYBRID HEARING)

Before: Shri T.R. Senthil Kumar, Judicial Member And Shri Bijayananda Pruseth, Accountant Member ITA No: 242 & 243/SRT/2025 Shri Vidhyasagar Sant CIT(Exemption), Nivas Trust Ahmedabad

4-C Prastavna Pratishtha Vs Complex, Parle Point, Surat-395007, Gujarat, India PAN: AAUTS1143E (Respondent)

(Appellant)

Assessee Represented: Shri Sapnesh Sheth, CA Revenue Represented: Shri Ashish Pophare, CIT-DR Date of hearing : 30-06-2025 Date of pronouncement : 24-07-2025 आदेश/ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

This appeal is filed by the Assessee as against the separate orders dated 28.12.2024 and 12-02-2025 passed by the Commissioner of Income Tax [Exemption] denying registration under section 12AB and under section 80G(5) of the Income Tax Act 1961 (hereinafter referred to as ‘the Act’).

2. The brief fact of the case is that the assessee filed Form 10AB for registration of the Trust u/s. 12AB of the Act. On perusal of the objects of the Trust, the Ld. CIT(E) found that the objects of the Trust are confined for the benefit of ‘Digamber Jain Community’ and not for the benefit of Public at Large, therefore a show ca