The Tribunal restored applications for registration u/s 12AB and approval u/s 80G to the CIT(E) for fresh adjudication after the assessee obtained the necessary registration under the Rajasthan Public Trust Act, 1959, which was the primary ground for the initial rejection.

ORDER

PER:

SHRI MAKARAND VASANT MAHADEOKAR, A.M. :

These four appeals by the same assessee, M/s Kheteshwar Gurukul Chhatrawas Samiti Maylawas, arise from two orders passed by the learned Commissioner of Income Tax (Exemption), Jaipur [“CIT(E)”], both dated 02.12.2024. Since the appeals arise from the same set of facts and involve interconnected issues concerning registration under section 12AB and approval under section 80G of the Income Tax Act, 1961 [“the Act”], they were heard together and are being disposed of by this common order.

2. The appeal-wise particulars are as under:

[[IMG_1]]

3. In ITA No. 945/Jodh/2024, the assessee has raised the following grounds of appeal:

1. That the Ld. CIT (Exemption), Jaipur has erred in law and in facts of the case by neither recording the independent satisfaction for rejection of provisional registration and nor issued Show Cause Notice for rejection of provisional registration u/s. 12A of the I.T. Act 1961 which is wrong, unwarranted and bad in Law. Kindly restore the same.

2. That the Ld. CIT (Exemption), Jaipur has erred in law and in facts of the case in rejecting the provisional registration u/s. 12A without issuing separate DIN of the rejection order, which is against the circular & notification issued by the CBDT. So, the same is wrong, unwarranted and bad in Law. Kindly restore the same.

3. That the order passed by Ld. Commissioner of Income Tax (Exemption), Jaipur by rejecting provisional registration u/s. 12A of the I.T. Act, 1961 is wrong, unwarranted and bad in law. Kindly direct to register the same.

4. That the appellant craves permission to add to or amend to any of the above grounds of appeal or to withdraw any of them.

4. In ITA No. 946/Jodh/2024, the assessee has raised the following grounds of appeal:

1. That the order passed by Ld. Commissioner of Income Tax, Exemption, Jaipur by rejecting application u/s. 12AB (1)(b) of the I.T. Act, 1961 is wrong, unwarranted and bad in law. Kindly direct to register the same.

2. That the appellant craves permission to add to or amend to any of the above grounds of appeal or to withdraw any of them.

5. In ITA No. 948/Jodh/2024, the assessee has raised the following grounds of appeal:

1. That the Ld. CIT (Exemption), Jaipur has erred in law and in facts of the case by neither recording the independent satisfaction for rejection of provisional approval and nor issued Show Cause Notice for rejection of provisional approval u/s. 80G of the I.T. Act 1961 which is wrong, unwarranted and bad in Law. Kindly restore the same.

2. That the Ld. CIT (Exemption), Jaipur has erred in law and in facts of the case in rejecting the provisional approval u/s. 80G without issuing separate DIN of the rejection order, which is against the circular & notification issued by the CBDT. So, the same is wrong, unwarranted and bad in Law. Kindly restore the same.

3. That the order passed by Ld. Commissioner of Income Tax (Exemption), Jaipur by rejecting provisional approval u/s. 80G of the I.T. Act, 1961 is wrong, unwarranted and bad in law. Kindly direct to register the same.

4. That the appellant craves permission to add to or amend to any of the above grounds of appeal or to withdraw any of them.

6. In ITA No. 949/Jodh/2024, the assessee has raised the following grounds of appeal:

1. That under the facts and in the circumstances of the case Ld. Commissioner of Income Tax, Exemption, Jaipur rejected