Assessee-trust filed an application for registration under section 12A Commissioner(E) issued show cause notice to verify genuineness of activities of assessee. After considering submissions of assessee, he rejected application on ground that charitable activities carried out by assessee-trust did not synchronize with financial statements and no credible evidence was furnished in support of charitable activities claimed. On appeal the Tribunal held that considering totality of facts of case and in interest of justice, assessee should be given one final opportunity to substantiate its case by filing requisite details to satisfaction of Commissioner(Exemption). Matter remanded.
Aress Foundation. v. CIT (E) (2025) 211 ITD 732 (Pune)(Trib.)
S. 12A : Registration-Trust or institution-Natural justice-Activities of the Trust-Directed to pass an order after giving an opportunity of hearing to the assessee. [S.80G]
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