2025 (12) TMI 393

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....ut providing adequate time for compliance with the notice dated 06.12,2024. The appellant acted promptly upon becoming aware of the notice and filed a request for an extension on the very same day 12.12.2024. The rejection order passed thereafter disregarded the appellant's timely request. This action is arbitrary and violates the principles of natural justice. The appellant had duly responded to previous notices dated 04.07.2024, 13.09.2024, and 18.11.2024, furnishing the required information. The omission to respond to the last notice was not intentional but due to unavoidable circumstances. This does not warrant outright rejection of the application. The appellant has complied substantially with the requirements under the Income Tax ....

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....r dated 12.11.2024 be set aside. 2. That the provisional registration under Section 80G(5)(iv) for Assessment Years 2023-24 to 2015-26 be restored. 3. That the application in Form 10AB be considered for approval under Section 80G(5)(iii). Judicial precedents support the view that technical or procedural lapses should not outweigh the substantive merits of a case. The rejection order disregards this principle. Accordingly, since the delay in responding to the notice was due to unavoidable circumstances. The appellant requests condonation of the delay and reconsideration of its application based on the merits. Since the provisional registration granted for AY 2023-24 till A Y 2015-26 has been cancelled by the officer, we req....