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Non-Compliance with Notices: ITAT Restores Trust Registration Matter to CIT(E) for Review

Case Law Details

TaxGuru Citation
2025 taxguru.in 69
Case Name
Satvic Movement Vs CIT(Exemption) (ITAT Delhi)
Date of Judgement/Order
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Satvic Movement Vs CIT(Exemption) (ITAT Delhi)

In the case of Satvic Movement vs. CIT(Exemption), the Income Tax Appellate Tribunal (ITAT) examined an appeal where the Commissioner of Income Tax (Exemption) (CIT(E)) had rejected the registration of a trust under Sections 12A and 80G(5) of the Income Tax Act, 1961. The rejection was based on the trust’s failure to comply with notices issued by the CIT(E), which required the submission of various documents and clarifications supporting the registration claims. The trust appealed, arguing that the CIT(E) had not provided sufficient opportunities to respond, violating the principles of natural justice. The appellant sought a remand of the matter for fresh consideration.

The ITAT reviewed the proceedings and agreed with the appellant’s argument that there was a lack of adequate opportunity for compliance with the notices. The Tribunal found it necessary to restore the matter to the CIT(E) to make a decision on the registration applications in accordance with the law, after providing the trust with an appropriate opportunity to be heard. The trust was also instructed to submit all relevant documents and details to support its registration claims. Consequently, the appeal was partly allowed, with the matter being sent back to the CIT(E) for a fresh review.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 20,897

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