This document summarizes the proceedings and decision of the Income Tax Appellate Tribunal, Delhi Bench, in the case between FP Life Education Foundation and the Commissioner of Income Tax (Exemption), New Delhi, concerning the assessment year 2022-23.
The case involves the appellant, FP Life Education Foundation’s appeal against the order of the learned Commissioner of Income Tax (Exemption), Delhi, dated September 19, 2022, which rejected the appellant’s application for registration under section 12AA of the Income Tax Act.
During the hearing, the appellant contended that the rejection of their application was unjust as they were not provided a fair opportunity to be heard, which is a cornerstone of judicial and administrative procedures. The Departmental Representative did not strongly contest this assertion, suggesting an openness to a re-evaluation of the case.
The Tribunal, led by Judicial Members G.S. Pannu and Saktijit Dey, observed discrepancies in the handling of the case by the CIT(Exemption), particularly the claims of not receiving notices for hearing. Acknowledging these procedural lapses, the Tribunal decided to set aside the CIT(Exemption)’s order and remanded the matter back for a fresh adjudication, ensuring that the appellant is provided a fair hearing.
The Tribunal’s decision emphasizes the importance of procedural fairness and the impact of administrative oversights on justice delivery. This case highlights the necessity for tax authorities to adhere to principles of natural justice, especially in matters involving the rights of taxpayers to fair hearings.
FP Life Education Foundation vs. CIT(E), New Delhi – ITA 2551/DEL/2022 for Assessment Year 2022-23
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