IN THE INCOME TAX APPELLATE TRIBUNAL “A’’BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA No. 264/Bang/2025 Assessment Year : NA Hands on CSR Trust No.7 Manasa Lake View Defence Colony Shettyhalli CIT (Exemptions)

Vs.

Jalahalli West Bangalore Bangalore Bangalore North 560 015 PAN NO : AACTH5677E APPELLANT RESPONDENT Appellant by : Sri Sampreeth B.S., A.R.

Respondent by : Sri Shivanand H Kalakeri, D.R.

Date of Hearing : 15.07.2025 Date of Pronouncement : 13.10.2025

O R D E R

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. CIT(Exemptions) Bangalore dated 17.12.2024 vide DIN & Notice No. ITBA/EXM/F/EXM45/2024- 25/1071305748(1) cancelling the registration u/s 12AB of the Income Tax Act, 1961 (in short “The Act”).

2. The assessee has raised the following grounds of appeal:

3. Brief facts of the case are that the assessee trust was constituted vide Deed of Trust dated 17.1.2022 at Bangalore with the object of carrying out Charitable activities, assisting people in development programs, activities in corporate social responsibility and in entrepreneurship promotion, thrift and micro-credit, technology, self-help, education and research, environment conservation and other general cause. The assessee Trust filed for provisional registration u/s 12AB of the Act on 11.8.2022 against which the provisional registration was granted in Form 10AC on 19.8.2022. Thereafter, the Trust commenced its activities on 1.4.2022 and accordingly filed Form 10AB on 29.6.2024 vide acknowledgement No. 532100490290624. On receipt of application in form 10AB dated 29.6.2024 for registration u/s 12AB of the Act, the case was assigned to the JAO for verification. On perusal of the submission made by the assessee, both the Range Head and JAO did not recommend for registration.

4. The ld. CIT(Exemptions) observed that the assessee trust has not made substantial amount of expenditure towards the objects and the assessee has not submitted any proof or evidence of activities and accordingly held that assessee has not commenced its activity towards the attainment of the objects. consequently, the ld. CIT(Exemptions) rejected the application in form no.10AB dated

29.6.2024 filed for registration u/s 12AB of the Act.

5. Aggrieved by the order of ld. CIT (Exemptions), the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paperbook comprising 34 pages containing therein Submissions of the assessee along with copy of the resolution of trustees & Annual report of activities (FY 2022-23).

6. The ld. A.R. of the assessee submitted that ld. CIT (Exemptions) erred in observing that assessee has not commenced its activities towards the attainment of the objects especially when the report of the AO and the Range Head as reproduced by the ld. CIT (Exemptions) are self-explanatory. Further, the ld. A.R. of the assessee submitted that the assessee trust had produced all the necessary documents/details as required for registration as the ld. CIT (Exemptions) herself in para 5 of the Order had observed that the assessee submitted all the necessary documents/details as required for registration u/s 12AB of the Act. Lastly, the ld. A.R. submitted that it is only the genuineness of the activities and not the quantum of expenditure which are relevant for granting registration u/s 12AB of the Act.

7. The ld. D.R. on the other hand supported the order of ld. CIT (Exemptions).

8. We have heard the rival submission and perused the materials available on record. On going through the order of ld. CIT (Exemptions), we take note of the fact that the ld. Jurisdictional assessing officer as well as Range Head had reported that the assessee trust had incurred major expenses towards “programme related expenses” of Rs. 24,90,805/- during the assessment year 2023-24. Similarly, for assessment year 2024-25, the expenses are booked for “project related