JUDGMENT D.N. Patel, J. – This Tax Appeal has been preferred against the judgment and order delivered by Income Tax Appellate Tribunal, Circuit Bench, Ranchi in ITA No. 164 /Ran/2010, whereby the application preferred by the respondent was allowed without assigning any reason and whatever factual aspects have been mentioned are absolutely false and wrong, as more than half a dozen cases have been decided at a time and the facts of other cases have been mixed up with the facts of the present case and wrongly the application has been allowed, as submitted by the counsel for the appellant, substantial question of law have been raised which are as under:- (i) Whether on the facts and in the circumstances of the Case the learned ITAT was justified in law in quashing the order u/s 12AA(3) of the I.T. Act, 1961 passed by the CIT without going in depth the basis of rejection taken by CIT? (ii) Whether on the facts and in the circumstances of the Case the learned ITAT has committed error in law in directing the CIT to grant registration u/s 12AA of the Act without verifying and establishing the genuineness of the actual activities of the Trust vis-a-vis its stated objectives and without appreciating weather the Trust fulfilled all essential ingredients for grant of registration or not? (iii) Whether on the facts and in the circumstances of the Case the learned ITAT has committed a gross error in ignoring the fact that a fair opportunity was given by the CIT to the Respondent Trust to establish genuineness of actual activities? (iv) Whether on the facts and in the circumstances of the Case the learned ITAT has committed a gross error in directing the CIT to grant registration u/s 12AA of the Act without appreciating the fact that the Trust made repeated non-compliance when called upon to prove and establish the genuineness of its actual activities vis-a-vis its stated objects which is essential conditions to be fulfilled for grant of Registration u/s 12 AA of the Act? (v) Whether on the facts and in the circumstances of the Case the learned ITAT was correct in not appreciating basic and specific procedure enshrined u/s 12AA(3) of the Act whereby the CIT rejected the registration after giving ample opportunity to establish the charitable nature of the Trust? (v) Whether on the facts and in the circumstances of the Case the learned ITAT was correct in not appreciating basic and specific procedure enshrined u/s 12AA(3) of the Act whereby the CIT rejected the registration after giving ample opportunity to establish the charitable nature of the Trust? (vi) Whether on the facts and in the circumstances of the case the ld. ITAT is correct in passing a common order involving other Assessee(s) having different issues? (vii) Whether on the facts and in the circumstances of the Case the impugned Order is perverse? 2. Having heard learned counsels for both sides and looking to the facts and circumstances of the case, combined and joint reasons given by Income Tax Appellate Tribunal in para-6 for half a dozen matters which are as under :- "6. On careful analysis of the order(s) passed by the ld. CIT(s) and the rival submissions of all the parties, it is found that the assessee society(s) was/were given registration under section 12AA and renewal was granted under section 80G for earlier years, therefore, it cannot be said that the material filed by the assessee(s) is incorrect. In this background, we are of the considered view that these are the fit cases to renew the registration of the Trusts and the impugned orders passed by the ld. CIT are not in accordance with law. Hence, the same are hereby set aside by directing the CIT(s) to renew the registration under section 80G and also grant of registration under section 12A/AA of the I.T. Act, 1961 as prayed for by the assessee(s) in different application(s), by allowing appeals of the assessee(s)." The aforesaid reasons have been given jointly for every matter by the Income Tax Appellate Tribunal, Circuit Bench, Ranchi including in ITA No. 164/Ran/2010. 3. It appears that the fact of the present case have not been appreciated in correct perspective at all. Earlier this respondent-Trust had preferred an application under Section 12 A of the Income Tax Act, 1961 and on 25.05.2002 registration u/s 12AA(1)(b) of the Act was granted which was cancelled u/s 12AA(3) of the Act on 25.05.2010 on the ground that the Respondent Trust has not carried out any charitable activity as envisaged in section 2(15) of the Income Tax Act, 1961. 4. 4. It further appears from the fact of the case that before cancellation of Registration u/s 12AA(3) on the Act on 25.05.2010, a Show Cause Notice was issued to the Respondent Trust on 11.02.2010 but the Respondent failed to file any reply of Show Cause and on every date the Respondent Trust filed Time Petition. The application trust completely failed to establish its charitable activities. In view of the same the registration granted u/s 12A of the Income Tax Act, 1961 was cancelled by the Commissioner. Being aggrieved and dissatisfied by the order passed by the Commissioner of Income Tax dated 25thth May, 2010, the respondent preferred appeal being ITA No. 164/Ran/2010 which has been allowed by the Income Tax Appellate Tribunal, Circuit Bench, Ranchi by an order dated 11thth July, 2011, with the only reason given in para-6 as quoted herein above. 5. Looking to the reasons given by Income Tax Appellate Tribunal, Circuit Bench, Ranchi in allowing the aforesaid ITA 164/Ran/2010, it appears that factually wrong aspects have been appreciated and wrongly this appeal has been allowed of the respondent. It has been observed by the Income Tax Appellate Tribunal that there was an application for renewal of the registration. It is factually a wrong aspect of the matter. 6. It ought to be kept in mind by the Income Tax Appellate Tribunal that whenever they decide more than one matter, all care should have been taken for factual aspects of each & every case, otherwise, this type of error is bound to occur. 7. In view of these facts, we, hereby, quash and set aside the order passed by the Income Tax Appellate Tribunal, Circuit Bench, Ranchi in ITA No. 164/Ran/2010 judgment and order dated 11thth July, 2011 and we hereby remand the matter to Income Tax Appellate Tribunal, Circuit Bench, Ranchi for its afresh decision. ITA No. 164/Ran/2010 is revived to its original file. The same will be decided on merit of the case and on the basis of the evidences on record. Substantial questions of law raised in this appeal are accordingly answered which are necessary for remand of the matter. 8. It is needless to say that Income Tax Appellate Tribunal, Circuit Bench, Ranchi will afford an opportunity of being heard to the respondent, who is appellant before the Income Tax Appellate Tribunal, in ITA No. 164/Ran/2010. Substantial questions of law raised in this appeal are accordingly answered which are necessary for remand of the matter. 8. It is needless to say that Income Tax Appellate Tribunal, Circuit Bench, Ranchi will afford an opportunity of being heard to the respondent, who is appellant before the Income Tax Appellate Tribunal, in ITA No. 164/Ran/2010. The respondent will also be permitted to adduce evidence if so required. 9. This Tax Appeal is allowed and disposed of.