ST BLASE S CHURCH,MUMBAI vs. COMMISSIONER OF INCOME EXEMPTIONS MUMBAI, MUMBAI

PER RATNA DASGPUTA, AM The present appeal by the assessee has arisen from the Ld. Commissioner of Income Tax (Exemption)’s – in short, CIT(E)’s – rejection, in Form 10AB, of the appellant’s application for renewal of registration u/s 12AB of the Income-tax Act (in short, ‘the Act’).

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It is against this rejection that the assessee is in appeal before this Tribunal. 2. The grounds of appeal raised by assessee are as under-; i. The Ld. CIT (Exemption), erred in passing order u/s. 12AA denying registration to the appellant u/s. 12AB of the Income tax Act, without specifying the conditions that were not complied with by the Appellant/assessee. ii. The Ld. CIT (Exemptions) was not justified in denying registration without putting the assessee to notice, as to what details were required to be filed by the Assessee with the Ld. CIT(E). iii. The Ld. CIT (Exemptions) misdirected himself in not specifying the details not filed by the assessee. iv. The Appellant craves leave to add/modify any grounds of appeal.

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3.1 It is Revenue’s contention that the assessee has not complied with all the terms of the said notice. Since registration u/s 12AB of the Act is to be granted in terms of provisions contained in Section 12AB(1)(b) after being satisfied about the objects of the trust, the genuineness of its activities, and compliance with any other law for the time being in force as are material for the purposes of achieving its objects, the CIT(E) could not arrive at a satisfactory conclusion in respect of these parameters in absence of necessary documents. He, therefore, rejected the application seeking renewal of registration. 3.2 The Ld. Authorized Representative (AR) of the assessee argued that the Ld. CIT(E) had denied the assessee registration without specifying what details had not been furnished by the assessee. His stand was that the Ld. CIT(E) was not justifying in denying registration to the assessee without specifying what conditions he wanted the assessee to comply with. 4. We have considered the submissions of both the parties in the light of the records placed before us. In Annexure to Form No. 10AB, the Ld. CIT(E) has noted that vide notice dated 15.11.2025, the assessee was requested to furnish complete set of documents/details as required under rule 17A(2). The said Rule provides that the application for registration of charitable or religious trusts, etc. shall be accompanied by a set of documents,

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as required by Form 10A or 10AB, as the case may be. These requirements are thereafter listed out in clauses ‘a’ to ‘k’ of Rule 17A(2). But, there is nothing on record to show which amongst the listed documents were not furnished by the assessee. 5. In view of the above, in the interest of justice, we remit the matter to the Ld. CIT(E) to give another opportunity to the assessee to furnish the necessary documents. The notice for giving opportunity shall specifically list out the documents/information that the assessee is required to furnish to eliminate any confusion as to what constitutes complete set of documents/details. 6. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open Court on 14/08/2026

Sd/- Sd/- (BEENA PILLAI) (RATNA DASGPUTA) JUDICIAL MEMBER ACCOUNTANT MEMBER Mumbai; Dated: 14/08/2026 Z.U., P.S.

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Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file.

BY ORDER,

//True Copy// (Assistant Registrar) ITAT, Mumbai