Rejection of 80G Renewal over Non-Response to Income Tax Notices in Spam Folder: ITAT Sets Aside CIT(E) Order

The Income Tax Appellate Tribunal (ITAT) has set aside an order by the Commissioner of Income Tax (Exemptions) that had rejected the renewal of an 80G registration for a trust. The rejection was based on the trust's failure to respond to income tax notices that had inadvertently landed in its spam email folder. The ITAT took a pragmatic view, recognizing that it is common for automated emails from government departments to be filtered into spam. The tribunal held that the non-response was not willful but a result of a genuine technical issue. It emphasized that a substantive benefit like an 80G registration, which is crucial for a charitable organization's fundraising, should not be denied due to such a procedural lapse. The matter was remanded for reconsideration on its merits, a decision that underscores the judiciary's preference for justice over technicalities, especially in cases involving charitable institutions.