AGRI SAMAJ UNNATI MANDAL BHIWANDI,BHIWANDI vs. CIT EXEMPTION PUNE, PUNE

Learned CIT-DR next submits that the CIT(E) herein has rightly declined to section 12A registration to the assessee on account of the fact that the latter head has failed to prove the commencement on its charitable activities. We note in this factual backdrop that the assessee has duly claimed to have completed “one of the projects” which has nowhere been considered in the learned CIT(E)’s order as per paras 6 to 6.1 in the impugned order. It further transpires that from perusal of the impugned order that the assessee had submitted its explanation on 05.03.2024 and thereafter, the CIT(E) never afforded it any further effective opportunities in support of its submissions. That being the clinching case, we deem it appropriate in the larger interest of justice to restore the assessee’s instant latter appeal back to the CIT(E) for his afresh appropriate adjudication preferably within three effective opportunities of hearing. Ordered accordingly.

These assessee’s instant former appeal herein is dismissed as a “duplicate” file and its latter case ITA No. 907/PUN/2024 is allowed for statistical purpose. A copy of this common order be placed in the respective case files.