IKIGAI KEN FOUNDATION,HYDERABAD vs. CIT (EXEMPTION), HYDERABAD

Facts

The assessee trust applied for registration under Section 80G of the Income Tax Act, 1961, in Form No. 10AB. The CIT(Exemptions) rejected the application, observing that no substantial charitable activities were carried out by the trust and failed to provide specific findings or objective analysis for the rejection.

Held

The Income Tax Appellate Tribunal (ITAT) found the CIT(Exemptions)'s order to be non-speaking, lacking specific findings, and without objective analysis of the submitted documents. The ITAT held that quasi-judicial authorities must pass reasoned orders and, therefore, restored the matter to the CIT(Exemptions) for fresh adjudication after providing a reasonable opportunity of being heard to the assessee trust.

Key Issues

Whether the CIT(Exemptions) passed a reasoned and speaking order with objective analysis when rejecting an application for 80G registration, and whether such rejection violated principles of natural justice.