SATPATI MANGELA SAMAJONNATI SANGH,PALGHAR vs. CIT EXEMPTION PUNE, PUNE

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ITA 5411/MUM/2026Status: DisposedITAT Mumbai15 September 2026AY 2026-273 pages
AI SummaryRemanded

What did the Tribunal hold?

The tribunal found that the assessee was not afforded a reasonable opportunity of being heard. Therefore, the case was remanded back to the CIT for a fresh decision.

What were the facts?

The assessee was granted provisional registration and applied for regularization. The CIT rejected the application, and the assessee claims they were not given an adequate opportunity to be heard.

What were the issues?

Whether the CIT properly accorded an opportunity of hearing to the assessee before rejecting the regularization of provisional registration.

Which sections of the Income-tax Act were involved?

Section 12AA

AI-generated summary — verify with the full judgment below

Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI PRABHASH SHANKAR

For Appellant: Shri Deepak Mhatre, AR
For Respondent: Shri Basavraj Hiremath (CIT-DR)
Hearing: 21.08.2026Pronounced: 15.09.2026

PER PRABHASH SHANKAR [A.M.] :- The present appeal is filed by the assessee against the order passed by the Learned Commissioner of Income-tax (Exemptions), Pune [hereinafter referred to as “CIT(E)”] pertaining to the order passed u/s. 12AA of the Income-tax Act, 1961 [hereinafter referred to as “Act”] for the Assessment Year [A.Y.] 2026-27. P a g e | 2 A.Y. 2026-27 Satpati Mangela Samajonnati Sangh 2. The assessee has contested the impugned order claiming that adequate opportunity of hearing was not accorded to it and the ld.CIT passed the order ex parte cancelling the provisional registration granted to it. In this case, the assessee was granted provisional registration on dated 03.01.2024 filed from AY 2024-25 to AY 2026-27 and therefore, the assessee filed an application for regularization of provisional registration before the ld. CIT who rejected the same vide impugned order dated 06.03.2026. 3. It was pleaded before us that though the notice calling for further was uploaded on ITBA Portal on 3.12.2025, however, no notice was sent otherwise to the assessee and therefore, it failed to comply with and/or filed the relevant submission and documents in order to substantiate the genuineness of its activities and requirements of any other law for the time being enforce.

4.

Considering the above facts, the case is remanded to the file of the ld.CIT(E) for decision afresh, suffice it to say by affording a reasonable opportunity of being heard to the assessee who is also directed to file all relevant documents without any delay or default. Both the parties agreed to such decision.

P a g e | 3 A.Y. 2026-27 Satpati Mangela Samajonnati Sangh 5. In the result, assessee's appeal is allowed for statistical purposes.

Order pronounced in the open court on 15/09/2026. (NARENDER KUMAR CHOUDHRY) ACCOUNTANT MEMBER

Place: म ुंबई/Mumbai ददनाुंक /Date 15.09.2026 Lubhna Shaikh / Steno

आदेश की प्रतितलति अग्रेतिि/Copy of the Order forwarded to : 1. अपीलार्थी / The Appellant 2. प्रत्यर्थी / The Respondent. 3. आयकर आयुक्त / CIT 4. विभागीय प्रविविवि, आयकर अपीलीय अविकरण DR, ITAT, Mumbai 5. गार्ड फाईल / Guard file. सत्यावपि प्रवि //// आदेशानुसार/ BY ORDER,

उि/सहायक िंजीकार (Dy./Asstt.

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