Artemis Education & Research Foundation v. CIT(E) (2022) 192 ITD 173 / 92 ITR 45 / 210 DTR 113 / 216 TTJ 58 (Delhi)(Trib.)

S. 80G : Donation-Bona fide reason that challenging rejection of application under section 12A is sufficient to cover rejection of approval under section 80G as well, is a reasonable reason to condone delay in filing appeal challenging rejection of application under section 80G. [S. 12A]

Adjudicating the matter in favor of the assessee, the Hon’ble Tribunal held that where assessee-trust was denied registration under section 12A and approval under section 80G and it filed an application seeking condonation of delay in filing appeal against rejection of approval under section 80G on ground that it had already filed an appeal challenging rejection of registration under section 12A and assessee was under a bona fide belief that same would be suffice to cover rejection of approval under section 80G as well, same was a reasonable ground, thus, delay was to be condoned.