, , आयकर अपीलीय अिधकरण इंदौर (cid:586)ायपीठ इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI BHAGIRATH MAL BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M JOSHI, JUDICIAL MEMBER ITA No. 408/Ind/2025 Madhya Pradesh Anusuchit CIT (Exemption)

Jaati Jan Jaati Evam Pichhda Bhopal Varg Kalyan Sangh, /

बनाम

166E, Muni Nagar, Vs.

Ujjain (Assessee/Appellant) (Revenue/Respondent)

PAN: AABAM1737C Assessee by Ms. Sonam Khandelwal, AR Revenue by Shri Anup Singh, CIT-DR Date of Hearing 27.11.2025 Date of Pronouncement 04.12.2025 आदेश / O R D E R Per Paresh M Joshi, J.M.:

This is an appeal filed by the Assessee Under Section 253 of the Income Tax Act, 1961 (hereinafter referred to as the Act for sake of brevity) before this Tribunal. The assessee is aggrieved by the order bearing Number: ITBA/EXM/F/EXM45/2024- 25/1071269250(1) dated 16.12.2024 passed by the Ld. CIT(E), Bhopal by virtue of which applications of the assessee in the form 10AB for grant the registration/approval u/s 12AB & 80G(5) of the Act were rejected and so also provisional Registration granted earlier were cancelled. The aforesaid order is hereinafter referred to as the “impugned order”.

2. FACTUAL MATRIX 2.1 The assessee had applied in form 10AB for registration u/s 12AB & 80G under the New Provision of the Income Tax Act 1961.

2.2 The assessee is a society registered under the societies Act.

2.3 That the in the “Impugned Order” the Ld. CIT(E) has recorded as under:

“Annexure (mentioned in row-9 above)

The assessee has applied in Form 10AB for registration u/ s 12AB & 80G under the new provision of Income Tax Act, 1961. Consequently, opportunity letters were issued to the assessee and various documents/ details were called for; to process the said application and to verify the objects and activities of the assessee. The details of opportunity letters and response received in compliance thereof are as under;

2-Vide above referred letters various documents/ information were called to ascertain the genuineness of the activities of the assessee society and its suitability to obtain registration/ approval u/ s 12AB & 80G of the Act The assessee has submitted some documents/ information in response to query letter dated: 04.10.2024 issued by this office. However, remaining documents and some clarifications/ additional documents were sought vide this office letter dated: 07:12:2024 as under "Please refer to your application in Form 10AB filed for registration/ approval u/ s 12AB & 80G under the new provisions of the Income Tax Act, 1961. In response to this office opportunity letter(s), you have submitted reply along with various documents.

Your submission has been perused by this office and you are required to provide following details/ information/ documents:

1-Audit Reports submitted by you in last submission are not legible. Therefore, you are requested to kindly furnish complete legible copies of Audit Reports with all annexures of the society and its 3 units (Schools) for last three years Le.

FY 2021-22, FY 2022-23 and FY 2023-24"

- on perusal of Audit Reports submitted by you, it is found that they are not certified by the Auditing Chartered Accountant by generating Unique Document Identification Number (UDIN)? Due to the aforesaid reason the Reports are not valid. Please submit your justification/ valid copies of Audit Reports.

2- Kindly furnish certified copies of grant letters/ work allocation order in support of the receipts under head "Grant in Aid" mentioned in your Audit Reports.

3-Vide S.No. 11 of this office letter dated: 04.10.2024, details in respect of educational institute was called as under "If educational institutions are running then produce copy of affiliation to run ed