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2024 (2) TMI 105

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....se two appeals filed by the assessee are directed against the orders of ld. Commissioner of Income Tax, Exemption, Pune [the CIT, Exemption] both dated 21.10.2023 denying registration u/s. 12AB(1)(ac)(vi) and approval u/s.80G(5)(iv) of the Income Tax Act, 1961 ('the Act'). 2. Briefly, the facts of the case are that the appellant is a trust engaged in the business of running educational institutio....

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.... is in appeal before us assailing the impugned orders passed rejecting the application u/s.12AB as well as approval u/s. 80G(5)(iv) of the Act. 3. We heard the rival submissions and perused the material on record. On perusal of the impugned order, it is clear that the appellant was asked to furnish certain information vide notice dated 13.10.2023 requesting the appellant society to file the detai....

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....e principles of natural justice. In the light of the aforesaid facts mentioned above, we find that the approach adopted by the ld. CIT, Exemption is unreasonable and violates of the principles of natural justice. In the circumstances, we are of the considered opinion that it is a fit case to remand the matter to the file of ld. CIT, Exemption for de novo consideration in accordance with law. Since....