Shenalma Gaushala Trust. v. CIT (E) (2025) 213 ITD 443 (Ahd) (Trib)

S. 12A: Registration –Trust or institution-Failure to respond to notices-Rural location and lack of access to digital infrastructure-Delay and default were neither deliberate nor contumacious-The matter was remanded back to the CIT (E) for a fresh decision.[80G]

Assessee, a public charitable trust, filed an application for registration under section 12A.CIT(E)  rejected the application on the ground that assessee had failed to respond to notices of hearing issued earlier and also rejected the assessee’s application for approval under section 80G on the identical ground of non-response and failure to establish the genuineness of activities and compliance with statutory conditions. Tribunal held that the delay and default, as demonstrated, were neither deliberate nor contumacious. Considering overall circumstances and in the interest of justice, the matter was remanded to the file of CIT E) to decide in accordance with law.

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