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2021 (5) TMI 995 - AT - Income TaxExemption u/s 11 - Registration application made u/s 12AA denied on the ground of non-submission of certain details - Denial of natural justice - HELD THAT:- On one hand the assessee contends that the provisions of principles of natural justices were not followed by the Department and the opportunity of hearing was not properly accorded to the assessee in this case and on the other hand, the facts demonstrate as from the order of the Ld. CIT (Exemption) that he could not arrive at proper satisfaction as regards the genuineness of the activities of the trust since the relevant details as called for by the Ld. CIT (Exemption) were not uploaded in the ITBA portal by the assessee. The provision of section 12AA of the Act mandates that the satisfaction has to be arrived at by the Ld. CIT (Exemption) before granting any registration under the said provisions. The satisfaction can only be arrived at once all the relevant details are placed before him - one more opportunity should be given to the assessee and accordingly, we set-aside the order of the Ld. CIT (Exemption) and restore the matter back to his file for re-adjudication while complying with the principles of natural justice - Appeal of the assessee is allowed for statistical purposes.
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