TMI Blog2019 (4) TMI 409X X X X Extracts X X X X X X X X Extracts X X X X ..... HELD THAT:- Show cause notice dated 11.09.2017 issued by the CIT(E) was received by the assessee only on 12.12.2017. Our attention was drawn to the date of receipt seal of the assessee in which the receipt of show cause notice issued by the CIT(E) dated 11.09.2017 is recorded as 12.12.2017. In the given facts and circumstances, we are satisfied that the assessee did not have proper opportunity of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 [ the Act ]. 2. The assessee is a charitable institution. It filed an application for grant of registration u/s. 12A of the Act on 31.03.2017. The CIT(E) issued a letter dated 11.09.2017 calling for certain details and fixed the date of hearing for compliance between 18th and 22nd Sept. 2017. It appears that till 22nd Sept. 2017, i.e., the last date fixed in the notice for giving the reply, t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 11.09.2017 is recorded as 12.12.2017. In the given facts and circumstances, we are satisfied that the assessee did not have proper opportunity of being heard before the CIT(E). We, therefore, set aside the order of CIT(E) and direct the CIT(E) to examine afresh the question of grant of registration u/s. 12A to the assessee, after affording proper opportunity of being heard. 5. In the resul ..... X X X X Extracts X X X X X X X X Extracts X X X X
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