2020 (11) TMI 261

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....eal filed by the assessee trust against the order of ld. Commissioner of Income Tax (Exemption), Pune dated 20.02.2019 passed u/s 12AA(1)(b)(ii) of the Income Tax Act, 1961 (for short "the Act") denying the registration u/s 12AA of the Act. 2. The appellant raised the following ground :- "Opportunity of being heard not granted." 3. The brief facts of the case are as under :- The ....

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....that the genuineness of the charitable activities carried out in last three years was not established and, therefore, rejected the grant of registration u/s 12AA of the Act vide order no.ITBA/EXM/S/EXM1/2018- 19/1015122692(1) dated 20.02.2019. 4. Being aggrieved by the order of ld. Commissioner of Income Tax (Exemption), the appellant is in appeal before us in the present appeal. Despite due se....

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....e, but from the perusal of the impugned order it is not clear that whether the ld. Commissioner of Income Tax (Exemption) had granted reasonable opportunity of being heard since the impugned order mentioned only one date of hearing notice. Furthermore, the Hon'ble Supreme Court in the case of Ananda Social and Educational Trust vs. CIT, 272 Taxman 7 held that even in the absence of any activities ....