ITAT Ahmedabad: Technical Difficulties and Lack of Litigation History Constitute Sufficient Cause for Delay Condonation

In a recent ruling, the Income Tax Appellate Tribunal (ITAT), Ahmedabad Bench, provided relief to a charitable institution by condoning a delay in filing an appeal and restoring the matter regarding registration under the Income Tax Act, 1961. The case, titled Gurudwara Sahib Shaheed Baba Deep Singhji Trust Vs CIT (Exemption), highlights the Tribunal's empathetic approach towards genuine technical difficulties faced by assessees in the digital compliance era.

The Tribunal set aside the ex-parte order passed by the Commissioner of Income Tax (Exemption) and directed a fresh adjudication on the application for registration under Section 12AB, subject to the payment of a nominal cost.

Background of the Dispute

The appeal was preferred by the assessee, Gurudwara Sahib Shaheed Baba Deep Singhji Trust, challenging an order dated 17.07.2025. This impugned order was passed ex-parte by the CIT (Exemption), Ahmedabad.

The core issue originated when the assessee trust, which held a provisional registration under Section 12AB, applied for regular registration by filing Form 10AB. The CIT (Exemption) rejected this application under Section 12A(1)(ac)(iii) of the Income Tax Act, 1961. Aggrieved by this rejection, the assessee approached the Tribunal, albeit with a delay.