2025 (5) TMI 104

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..... 25 dated 12.09.2024 and 09.09.2024, respectively. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: I.T.A. No.: 246 /GTY/2024 "1. Inadequate Opportunity Provided by CIT(Exemptions) The Appellant respectfully submits that adequate opportunity was not provided to furnish all necessary documents. Due to a limited timeframe and procedural constraints, the Appellant was unable to gather the required documentation within the deadline imposed. The Appellant submits that this restricted timeframe prevented them from demonstrating their eligibility for registration under Section 80G(5) of the Income Tax Act,1961. 2. Lack of Legal Assistance and Guidance The Appellant faced challenges in procuring s .....

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..... personal hearing and to allow the submission of all supporting documents, which substantiate the Appellant's claim for registration under Section 80G." I.T.A. No.: 247/GTY/2024 "1. Inadequate Opportunity Provided by CIT(Exemptions) The Appellant respectfully submits that adequate opportunity was not provided to furnish all necessary documents. Due to a limited timeframe and procedural constraints, the Appellant was unable to gather the required documentation within the deadline imposed. The Appellant submits that this restricted timeframe prevented them from demonstrating their eligibility for registration under section 12A(1)(ac)(iii) of the Income Tax Act, 1961. 2. Lack of Legal Assistance and Guidance The Appellant faced .....

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..... the Hon'ble Tribunal to grant an opportunity for a personal hearing and to allow the submission of all supporting documents, which substantiate the Appellant's claim for registration under Section 12A(1)(ac)(iii)." 3. Rival contentions were heard and the submissions made have been examined. During the course of the appeals, though the assessee sought adjournment, however, the Bench was of the view that the Ld. CIT(A) had denied the claim of exemption u/s 80G as well as 12AA of the Act on account of non-compliance by the assessee. Therefore, in the interest of justice, it was considered imperative that the assessee may be granted another opportunity to file its submission in response to the notice issued by the Ld. CIT (Exemption) .....

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