ITAT Jaipur Judgments — November 2024

The Tribunal noted that the assessee raised a contention regarding the violation of principles of natural justice and a lack of adequate opportunity to be heard. The Tribunal also observed that the assessee had subsequently obtained registration under the Rajasthan Public Trust Act. Considering these aspects and the curable nature of the deficiencies, the Tribunal decided to remand the matter back to the CIT(E) for fresh adjudication.

The Tribunal noted that the time limits prescribed for filing the application under section 80G were mandatory and the CIT(E) initially had no power to condone the delay. However, considering the subsequent CBDT circulars that extended the time limit for such applications, the Tribunal found that the benefit of these extensions should be extended to the assessee.