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Therefore, I find that the above stated facts and circumstances would show that the petitioner has explained the delay in filing the Form 10 satisfactorily. Therefore, the first respondent is not justified in rejecting the application for condonation of delay, simply by saying that the petitioner has not satisfactorily explained the delay.

Shanti Prime Publication Pvt. Ltd.

Section 11 & 12AA of the Income-tax Act, 1961—Charitable or religious trust—AO is not justified in rejecting the application for condonation of delay, simply by saying that the assessee has not satisfactorily explained the delay, however, though the delay is condonable, it is for the assessee to establish before the AO that accumulated income was utilised for the subsequent years only for the purpose for which the assessee trust was established, therefore, such liability exists on the assessee which they have to discharge before the AO - COIMBATORE MUSLIM RELIEF FUND V/s DIT - [2019] 267 TAXMAN 399 (MAD)

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