Summary
- The Bangalore ITAT has ruled that the CIT(A) cannot rely on a system-generated delivery report without giving the assessee, Sacred Trust Registered, an opportunity to respond.
- The trust's appeal against a delayed exemption claim under section 10(23C)(iiiad) was dismissed due to a purported 2,120-day delay, which the ITAT found unjustified.
- The Tribunal emphasized the violation of natural justice principles and restored the matter for fresh consideration by the CIT(A).
- This ruling underscores the necessity for fair hearing procedures in tax appeals, potentially impacting future cases involving similar issues.
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