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TMI Blog2020 (11) TMI 261X X X X Extracts X X X X X X X X Extracts X X X X ..... st 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 appellant is a company registered under the provi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 service of notice, none appeared on behalf of the ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot 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 a trust can be considered for registration u/s 12AA o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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