2021 (7) TMI 709

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.... granting registration under section 80G & 12AA of the Income Tax Act, 1961 [hereinafter referred to as 'the Act'], both the applications were dismissed by ld CIT(E) on identical observation. Therefore, with the consent of parties, both the appeals were clubbed, heard and are decided by consolidated order to avoid the conflicting decision. For appreciation of fact, the fact in ITA No. 23/SRT/2021 is treated as lead case. The assessee has raised the following grounds of appeal: The ld. CIT(E) was not just and proper on the facts of the case and in law in rejecting the application of the Trust for registration u/s. 80(G).* (* wrongly mentioned 12AA.) 2. Brief facts of the case are that the assessee is a charitable....

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....of the assessee and ld. Departmental Representative (CIT-DR) for the Revenue and perused the material available on record. The ld. AR of the assessee submits that assessee has not received any notice as noted by ld. CIT(E) in the impugned order. The assessee on accessing the ITBA portal find that the address of email through which notice was allegedly send by ld. CIT(E) was wrongly mentioned as [email protected], however, the email address of assessee is [email protected]. The ld. AR for the assessee, accordingly submits that due to mentioning wrong email address, no notice was received by assessee and the assessee was prevented by sufficient cause for not responding to the notice issued by ld. CIT(E). The ld. AR for the assessee ....