SREERAM BHAGAWATHI AYYAPPA SEVA TRUST,KAKINADA vs. INCOME TAX OFFICER, KAKINADA

Facts

The assessee trust, after receiving provisional registration under Sections 12A and 80G of the Act, applied for permanent registration under Sections 12AB and 80G(5). The CIT(Exemption) rejected both applications via orders dated 13.02.2025, despite the assessee providing various documents, stating that only partial information was furnished and activities were not commensurate with objectives.

Held

The tribunal held that the CIT(Exemption)'s rejection orders were 'non-speaking, cryptic, and mechanical,' violating the principles of natural justice. It found that the CIT(Exemption) failed to substantiate its claims or specify missing information, thus rendering the orders unsustainable in law.

Key Issues

Whether the CIT(Exemption) erred in rejecting the assessee trust's applications for permanent registration under Sections 12AB and 80G(5) without passing a reasoned order or providing an opportunity for clarification, thereby violating natural justice.