IN THE INCOME TAX APPELLATE TRIBUNAL “NAGPUR” BENCH, NAGPUR BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER &

SHRI KHETTRA MOHAN ROY, ACCOUNTANT MEMBER ITA No. 601/NAG/2024 (A.Y. 2024-25)

(Physical hearing)

C.S.C., Education Society, CIT(Exemption), GTA and Co. LLP, 1^st Floor, Vs Income Tax Office, PMT Building, Cathedral Building, Residency Shankar Sheth Road, Pune -

Road, Sadar, Nagpur 440001. 411037 PAN : AAATC 6065 B Appellant / Assessee Respondent / Revenue ITA No. 602/NAG/2024 (A.Y. 2024-25)

Asha Niketan Church Society, ITO Ward -3, Exemption, GTA & CO. LLP., Chartered Vs BSNL RTTC Building, Seminary Accountant, 1^stFloor Cathedral Hills, Nagpur, Maharashtra, Building, Residency Road, Sadar, 440006.

Nagpur, Maharashtra, 440001.

PAN : AABTA3428M Appellant / Assessee Respondent / Revenue ITA No. 603/NAG/2024 (A.Y. 2024-25)

Harvest Mission for Christ in ITO WARD-1, Exemption, India, Vs BSNL, RTTC BUILDING,, NAGPUR, GTA & CO. LLP., Chartered Maharashtra, 440006 Accountant, 1^stFloor Cathedral Building, Residency Road, Sadar, Nagpur MS 440001, Nagpur, Maharashtra, 440013.

PAN : AAATH2760C Appellant / Assessee Respondent / Revenue

1. These four appeals by different society-trust (assessee) are directed against the separate orders of ld. Commissioner of Income Tax (Exemption) [for short “CIT(E)”] rejecting application for registration of Trust/ society under section 12AB. Facts in all the appeals are similar, all the appellants/ assessees have raised certain similar grounds of appeal, therefore, with the consent of both the parties, both the appeals were heard together. For appreciation of facts, the appeal in ITA No 601/Nag/2024 is treated as lead case.

2. Rival submissions of both the parties have been heard and record perused.

The ld. Authorised Representative (AR) of the assessee submits that assessee is a charitable Trust /Institution, filed application for registration of Trust under section 12AA/12AB on 27.03.2024. At the time of filing online application, the assessee furnished all the required evidence and information.

In response to show cause notice by ld. CIT(E) the assessee again furnished required details. The ld. A.R. submits that once the assessee furnished evidence about the object and activities, the assessee is eligible for registration under section 12AB. The ld. AR of the assessee prayed for allowing all the appeals with direction to ld. CIT(E) for granting registration forthwith. In alternative and without prejudice submission, the ld. AR of the assessee submits that all the appeals may be restored to the file of ld. CIT(E)

for passing the order afresh, after considering the evidence on record.

3. On the other hand, ld. CIT–DR for revenue submits that assessee has not responded in response to notice issued by CIT(E). the ld. CIT(E) in his finding has clearly recorded that the assessee failed to furnish required evidence, the assessee in its reply dated 22.09.2024, did not furnish point wise (issue wise) reply response to show cause as it has been clearly recorded in para- 6. Thus, from the conduct of assessee it was clear that they are not interested in furnishing the required evidence to substantiate object, activities and compliance on any other law, entitling them for registration under section 12AB, therefore, all the assessees are not eligible for any relief from this Tribunal. All the appeals may be dismissed.

4. We have considered the rival submissions of both the parties and have gone through the orders of lower authorities carefully. On perusal of impugned order passed by ld. CIT(E), we find that at the time of the filing appli