PARAMOUNT PUBLIC SCHOOL EDUCATIONAL SOCIETY,ROHTAK HARYANA vs. CIT EXEMPTIONS CHANDIGARH, CHANDIGARH

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ITA 3210/DEL/2026Status: DisposedITAT Delhi19 August 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the assessee was not given a proper opportunity to be heard and that complete details were not filed. Therefore, the order of the CIT(Exemption) was set aside.

What were the facts?

The assessee, Paramount Public School, applied for registration under Section 12A(1)(ac)(ii) of the Income Tax Act. The CIT(Exemption) rejected the application, citing non-production of necessary documentary evidence regarding loans given for educational purposes.

What were the issues?

Whether the CIT(Exemption) correctly rejected the registration application without providing adequate opportunity for the assessee to submit all required evidence.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘G’: NEW DELHI

For Respondent: Shri Jadhav Shukracharya Krupacharaya
Hearing: 29/07/2026Pronounced: 29/07/2026

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.3210/Del/2026 (ASSESSMENT YEAR: NA) Paramount Public School CIT(Exemption), Educational Society, Chandigarh. 698/10, Shora Kothi, Vs. Rohtak, Haryana-124001. PAN-AABAP1789K (Appellant) (Respondent) Assessee by None Department by Shri Jadhav Shukracharya Krupacharaya, CIT-DR Date of Hearing 29/07/2026 Date of Pronouncement 29/07/2026 O R D E R PER MANISH AGARWAL, AM: This appeal is filed by the assessee against the order of the Ld. Commissioner of Income Tax (Exemption), Chandigarh [CIT(E), in short] in DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/1086206306(1) dt. 18.02.2026 rejecting the registration u/s 12A(1)(ac)(ii) of the Income Tax Act, 1961 (hereinafter referred as ‘the Act’). 2. In the instant case, the assessee had filed application on 29.09.2025 for registration u/s. 12A(1)(ac)(iii) of the Act before the ld. CIT(E). It was the submission that ld. CIT(E) issued notice to the assessee and call for certain explanation, asked for producing supporting documentary evidence, loan

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agreements, confirmations, and justification regarding loans to related parties. It was the submission of the appellant that advances were given for educational purposes and in furtherance of the charitable objects of the trust. The applicant stated that such loans were given to facilitate educational activities and that invoices had not yet been raised by the concerned parties. It was the submission that the loans were given to facilitate educational activities which were utilized in day to day activity which have not been considered by ld. CIT(E). It was the submission that it was in this backdrop that the Ld. CIT(E) rejected the application and dismissed the application filed by the assessee. Ld. AR prayed that the appellant trust may be granted registration u/s.12A(1)(ac)(iii) of the Act.

3.

In reply, ld. CIT-DR objected to the grant of registration and requested that the matter may be sent back to the file of ld. CIT(E) for reconsideration of the submissions made by the assessee.

4.

We have considered the rival submissions. Ld. CIT(Exemption), Chandigarh has rejected the applications filed by assessee for non-production of the necessary evidences for carrying out of the educational activities. A perusal of the impugned order of ld. CIT(E), Chandigarh clearly shows that notice was issued to the assessee through e-filing portal to furnish the detailed reply on the specific information called for. The appellant trust filed certain information however the complete details were not filed, thus, the application for registration u/s. 12A(1)(ac)(iii) was rejected by the ld. CIT(E). ld. AR submits that the appellant trust has filed all the evidences as sought by ld. CIT(E) who has failed to appreciate the same. We are of the view that proper opportunity of being heard was not provided to the assessee and hence, in the interest of justice, we set aside the order of CIT(E) and remit the issue back to the file of the CIT(E), with the

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directions to examine all the details filed by the assessee and assessee is also directed to file further details/ information, if required, to the satisfaction of ld. CIT(E). All the grounds of appeal of the assessee are allowed for statistical purposes.

5.

In the result, appeal of the assessee stands allowed for statistical purposes. Order pronounced in the open court on 29.07.2026.

Sd/- Sd/-- (ANUBHAV SHARMA) (MANISH AGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 19.08.2026 *PK, Sr. P.S* Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI

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