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Facts
The assessee trust's appeal was filed 111 days late. The delay was due to the assessee's belief that it held registration under Section 12AB, ignorance of notices served via e-portal, and the counsel's personal issues. The CIT(Exemptions) had passed an ex-parte order rejecting the registration application.
Held
The Tribunal condoned the delay, finding reasonable cause for the same, and admitted the appeal. The matter was remitted back to the CIT(Exemptions) for fresh adjudication, ensuring the assessee gets a proper opportunity to be heard.
Key Issues
Whether the delay in filing the appeal is to be condoned and if the ex-parte order passed by the CIT(Exemptions) violates the principles of natural justice.
Sections Cited
12AB, 253(5), 282
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िनधा"रती की ओर से/Assessee by : Shri Ashok Goyal, C.A राज" की ओर से/ Revenue by : Shri Manav Bansal, CIT, DR सुनवाई की तारीख/Date of Hearing : 04/11/2025 उदघोषणा की तारीख/Date of Pronouncement : 28/11/2025 आदेश/Order PER KRINWANT SAHAY, J.M: This is an appeal filed by the the assessee trust against the order of the Ld. CIT Exemptions, Chandigarh dt. 09/01/2023.
2. At the outset, the Registry has pointed out that the present appeal is time- barred by 111 days. In light of this, the assessee has submitted an application requesting the condonation of the delay in filing the appeal. The relevant contents of this condonation application read as follows:
That your kind attention is drawn towards the fact that Ell Aar Memorial Educational Trust is a trust registered under Sub