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TMI Blog2021 (1) TMI 612X X X X Extracts X X X X X X X X Extracts X X X X ..... ish the details called for by the Ld. CIT(Exemption) and uploaded the same in the Department's portal. This non-compliance is definitely not deliberate or intentional rather possibly due to prevailing circumstances. As known principle recognized by the Higher Judicial Forums and even by the Tribunal that Income Tax Legislation is a part and parcel of welfare legislation where the interest of the tax payers needs to be protected. One more opportunity should be given to the assessee to furnish requisite details/evidences before the Ld. CIT(Exemption) so that the case may be represented on merits and thereafter, the Ld. CIT(Exemption) shall adjudicate the matter while complying with the principles of natural justice.Appeal of the assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th the Deptt. in the form of Returns of Income and copies of accounts as attachments to the Audit reports as per F.No. 10B which show the correct affairs of the assessee. On the facts and circumstances of the case and in law the CIT.E has incorrectly compared the figures of FY 2018-19 and 2019-20 without appreciating the fact that the figures for FY 2018-19 represented application of funds whereas figures for FY 2019-20 represented the net surplus after application of funds and accordingly inferred that income shown for FY 2019-20 is very low. The appellant craves leave for adding, altering, modifying or deleting any of the grounds on or before the date of hearing 2. At the time of hearing, none appeared on behalf of the asse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the year 2020-21 on 29.02.2020. Thereafter, whatever notices were issued to the assessee asking them to furnish all the requisite details/evidences, that was the time when pandemic was at its peak. That various offices were closed and there was no communication with people whatsoever and the entire working atmosphere was brought to a standstill. In such scenario, it was quite possible that the assessee was unable to furnish the details called for by the Ld. CIT(Exemption) and uploaded the same in the Department's portal. This non-compliance is definitely not deliberate or intentional rather possibly due to prevailing circumstances. 5.1. It is well known principle recognized by the Higher Judicial Forums and even by the Tribunal that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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