Ram Bhakt Mandal Trust Vs CIT (Exemption) (ITAT Ahmedabad)
Income Tax Appellate Tribunal (ITAT) Ahmedabad Bench has overturned an order by the Commissioner of Income Tax (Exemptions) [CIT(E)], restoring the applications of Ram Bhakt Mandal Trust for registration under Sections 12AB and 80G of the Income Tax Act, 1961. The tribunal’s decision comes with a condition: the trust must deposit Rs. 10,000 as costs to the Prime Minister’s Relief Fund, acknowledging its non-compliance during the initial proceedings.
The trust had filed appeals against the CIT(E)’s orders dated September 3, 2024, which rejected its applications for tax exemption registrations. The primary reason for the rejection was the trust’s failure to respond to information requests and appear for hearings before the CIT(E).
At the outset of the ITAT proceedings, the trust sought condonation for a significant delay of 165 days in filing its appeals. Counsel for the trust explained that the trustees were elderly individuals, all over 70 years old, facing health issues, and not proficient with technology, which prevented them from accessing their email IDs. A crucial point of contention was that the email ID registered on the Income Tax portal belonged to the trust’s accountant. It was contended that due to financial difficulties, the trust could not pay the accountant’s fees, leading the accountant to neglect informing the trust about the notices issued by the CIT(E) or pursuing the appeals within the stipulated time.
