WORLD LIFE FOUDATION,CHENNAI vs. CIT-E,XEMPTIONS, CHENNAI

आदेश / O R D E R

PER ABY T. VARKEY, JM: This is an appeal preferred by the assessee foundation against the

order of the Learned Commissioner of Income Tax (Exemptions)/NFAC,

(hereinafter in short "the Ld.CIT(E)”), Chennai, dated 25.01.2024 against

the action of the Ld.CIT(E) rejecting the application filed online on

28.08.2023 in Form No.10AB u/s.12A(1)(ac)(iii) of the Income Tax Act,

1961 (hereinafter in short "the Act”).

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the assessee to file the “objects of the Trust/Institution”, so that he could

verify as to whether the assessee is a charitable organization or not ? And

he also directed the assessee to prove the genuineness of its activities,

and asked the assessee to file documents as prescribed under Rule 17A of

the Income Tax Rules, 1962 (hereinafter in short ‘the Rules’) including

Note on activities and Annual Accounts/Financial Statements of the

Institution. However, according to the Ld.CIT(E) despite issuing notice on

two occasions i.e. on 21.12.2023 & 09.01.2024 and even after giving final

opportunity on 18.01.2024, he found no response from assessee. So, he

rejected the application filed by assessee for non-compliance to his

aforesaid directions. Before us, the assessee pleads that non-compliance

to Ld.CIT(E)’s notice was not deliberate, but the reasons for non-

compliance was, because, the assessee didn’t get the copy of the notices

may be due to glitches in the internet/computer or served to wrong email

id supra; and pleaded for one more opportunity before the Ld.CIT(E) and

the Ld.AR undertakes to file all the requisite documents as required under

Rule 17A and other documents called for by the Ld.CIT(E). In the light of

the undertaking given before us, we are inclined to give one more

opportunity to the assessee-foundation, and set aside the impugned order

of the Ld.CIT(E) and restore the application filed by the assessee for

registration u/s.12AB of the Act and direct the assessee to file all relevant

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documents called for by the Ld.CIT(E) (as stated in the impugned order of the Ld.CIT(E)); and the Ld.CIT(E) to decide the application of assessee on merits after giving proper opportunity to assessee and in accordance to law.

Order pronounced on the 25th day of June, 2024, in Chennai.

Sd/- Sd/- (मनोज कुमार अ�वाल) (एबी टी. वक�) (MANOJ KUMAR AGGARWAL) (ABY T. VARKEY) लेखा सद�य/ACCOUNTANT MEMBER �याियक सद�य/JUDICIAL MEMBER

चे�ई/Chennai, �दनांक/Dated: 25th June, 2024. TLN, Sr.PS आदेश क� �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF