AMBALA MERCY HOME SOCIETY,AMBALA CITY, HARYANA vs. INCOME TAX OFFICER, EXEMPTION, AMBALA, HARYANA

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM 1. आयकरअपीलसं. / ITA No.1524/CHANDI/2026 & 2. आयकरअपीलसं. / ITA No.1525/CHANDI/2026 Ambala Mercy Home Society CIT (Exemptions) बनाम/ Near JD Farm, Panjokhra Road Sector 17 Chandigarh - 160017 Ambala, Mahesh Nagar Vs. S.O, Ambala City, Haryana – 133001 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AACAA-5778-J (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Ms. Khushboo (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Jaishree Sharma (CIT) - Ld. DR सुनवाईकीतारीख/Date of Hearing : 13-08-2026 घोषणाकीतारीख /Date of Pronouncement 17-08-2026 : आदेश / O R D E R Per Bench 1. Aggrieved by rejection of an application as filed by the assessee seeking registration u/s 12A(1)(ac)(iii) and consequential rejection of application seeking registration u/s 80G(5) vide impugned orders dated 04.11.2025 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeals before us. The registry has noted delay of 125 days in the appeals, the condonation of

which has been sought by Ld. AR on the strength of condonation petition which is accompanied by an affidavit of President of assessee- trust. In the petition, it has been stated that the key person of the trust was suffering from serious health ailments which led to delay in the appeal. On merits, Ld. AR has prayed for remand back of the matter to Ld. CIT(E) to enable the assessee to substantiate its case which has been opposed by Ld. CIT-DR. 2. Upon perusal of Para 3.2 of the impugned order rejecting assessee’s registration application u/s 12A(1)(ac)(iii), it could be seen that the application has been rejected on the ground that the assessee did not furnish corroborative evidence such as bills, invoices, relevant photographs, beneficiary list or other verifiable records to substantiate its expenditure. Therefore, the genuineness of the activities could not be ascertained. Accordingly, both the registration as well as approval was denied against which the assessee is in further appeals before us. The Ld. AR has stated that the assessee is in a position to substantiate its activities and a prayer has been made before us to remand back the applications which have been opposed by Ld. CIT-DR. 3. Keeping in mind the principles of natural justice and in view of the fact that the assessee is a charitable trust, we admit the appeals and accept the prayer of Ld. AR. Accordingly, the impugned orders are set aside and the issue of registrations / approval stand restored back to Ld. CIT(E) for fresh adjudication with a direction to the assessee to plead and prove its cases establishing genuineness of the activities of the assessee-trust.

-Sd- -Sd- (RAJESH DAMODARLAL SHARMA) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 17-08-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

BY ORDER ASSISTANT REGISTRAR INCOME TAX APPELLATE TRIBUNAL KENDRIYA SADAN, SECTOR – 9A CHANDIGARH