THE SISTERS OF CHARITY EDUCATIONAL (BOMBAY) SOCIETY,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI

PER SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER: This appeal is filed by the assessee against the order of the learned CIT(E), Mumbai, dated 25.03.2026 in denying registration under section 12AB of the Act.

ITA 4296/MUM/2026 THE SISTERS OF CHARITY EDUCATIONAL (BOMBAY) SOCIETY 2. In spite of issue of notice, none appeared on behalf of the assessee nor any adjournment was sought. We dispose of the appeal after hearing the learned DR.

“Ground - A. On the facts and circumstances of the case and in law, the learned CIT(E) (the “AO”) erred in rejecting application u/s 12AB of the Act on the ground of non-furnishing of proof of activities. B. On the facts and circumstances of the case and in law the CIT(E) failed to appreciate that i. The assessee had duly furnished all requisite documents, information, and evidences as required. ii. The AO dismissed the application without issuing show cause notice to the assessee thus without providing an opportunity to the assessee iii. AO did not specify any particular deficiency OR shortcoming in the submissions made by the assessee, arbitrarily dismissed the application. iv. AO failed the appreciate that the assessee has submitted all the relevant supporting and proofs towards the activities undertaken by the trust. C. The Appellant therefore prays that application for registration may be approved.” 4. On perusal of the order passed by the learned CIT(E), it is noticed that the registration under section 12AB of the Act was denied to the assessee on the ground that the assessee could not provide the details as requested in the notice dated 12.01.2026. It is also observed from the order of the learned CIT(E) that the assessee filed its submissions on 03.02.2026 and 17.02.2026. In the grounds of appeal raised before us, the assessee contended that the assessee had furnished all the requisite details/documents/information as required. It was also the contention of

ITA 4296/MUM/2026 THE SISTERS OF CHARITY EDUCATIONAL (BOMBAY) SOCIETY the assessee that the learned CIT(E) dismissed the application of the assessee after providing inadequate opportunity to the assessee.

Order pronounced in the open court on 12/08/2026

Sd/- Sd/- MAKARAND VASANT MAHADEOKAR CHALLA NAGENDRA PRASAD ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai, Dated: 12/08/2026 Prabhat

ITA 4296/MUM/2026 THE SISTERS OF CHARITY EDUCATIONAL (BOMBAY) SOCIETY

Copy to: THE SISTERS OF CHARITY EDUCATIONAL (BOMBAY) SOCIETY, THE SISTERS OF CHARITY 1 EDUCATIONAL (BOMBAY) SOCIETY P. BALU MARG PRABHADEVI ,MUMBAI, MUMBAI-400025, MAHARASHTRA CIT (EXEMPTIONS), 6TH FLOOR, MTNL TE BUILDING, 2 CUMBALLA HILL, PEDDER ROAD, MUMBAI, MUMBAI-400026, MAHARASHTRA 3 THE PCIT / CIT, 4 THE D.R., ITAT, MUMBAI BENCH 5 GUARD FILE