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TMI Blog2023 (9) TMI 1509X X X X Extracts X X X X X X X X Extracts X X X X ..... the mobile number uploaded in the PAN profile of the assessee. HELD THAT:- On a perusal of the copies of the notices it is apparent that the registered email id of the assessee were missing, therefore, the assessee s claim that such notices were never delivered in the email id of the assessee, could not be discarded. Under such circumstances, in the interest of justice and respectfully following the decision of Suman Jeet Agarwal [ 2022 (9) TMI 1384 - DELHI HIGH COURT] we are of the considered view that in all fairness the matter should be restored to the file of the CIT(Exemption) so that application of the assessee can be considered in light of the evidence /information/explanation /submission of the assessee. We order accordingly. Appeal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... alled for to process the application and to verify the object and activities of the assessee. In response to the letter, the assessee has not submitted the requisite documents. Considering the aforesaid facts, the CIT(Exemption) was of the view that the application of the assessee cannot be processed due to non-compliance of the assessee, thus, the same is hereby rejected. 4. Aggrieved with the order of the CIT(Exemption), the assessee carried the matter in appeal before us. 5. At the very outset, the Ld. AR for the assessee drew our attention to the copies of the notices issued to the assessee on 06.04.2023, 15.05.2023 and 30.05.2023 by the office of the CIT(Exemption), Bhopal pertains to the application of the assessee for registration /a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and for communication in electronic form the e-mail should have been despatched on or before 31st March 2021. 6. It was submitted by the Ld. AR that since the assessee was prevented by reasonable cause that the notices issued by the Ld.CIT(Exemption), Bhopal were neither communicated to the assessee on the registered email id of the assessee i.e. [email protected] nor through real time alerts, thus, the application of the assessee for granting of registration which was rejected by the Ld. CIT(Exemption) was without adequate or proper opportunity to the assessee and therefore, the assessee may be allowed another opportunity to represent its case on merits before the CIT(Exemption). 7. Contrary to the submissions of the Ld. AR, the Ld. CIT- ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l v. ITO - [2022] 143 taxmann.com 11 (Delhi), we are of the considered view that in all fairness the matter should be restored to the file of the CIT(Exemption) so that application of the assessee can be considered in light of the evidence /information/explanation /submission of the assessee. We order accordingly. Needless to say, the Ld. CIT(Exemption) shall grant reasonable opportunity of being heard to the assessee who shall remain at liberty to substantiate its claim on the basis of supporting documentary evidence. The assessee is also directed to make necessary compliances as and when called for failing which the Ld. CIT(Exemption) would be at liberty to dispose of the application in accordance with law. 9. In the result, appeal of the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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