SOCIETY FOR CONSERVATION OF NATURE (PRAKRITI ),DELHI vs. CIT (EXEMPTION), DELHI

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, G: NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA No.- 1493/Del/2026 [Assessment Year: -] ITA No.- 1494/Del/2026 [Assessment Year: -] Society for Conservative of Nature Commissioner of Income Tax (PRAKRITI), (Exemption), 40, SFS Hauz Khaz, Apartments, Vs Civic Centre, Minto Road, New Shri Arobindo Marg, New Delhi- Delhi-110002. 110016. PAN- AAEAS9045E Assessee Revenue Assessee by None Revenue by Shri Lalit Mohan Jindal, CIT(DR) Date of Hearing 03.08.2026 Date of Pronouncement 03.08.2026 ORDER Per Renu Jauhri, Accountant Member:

These two appeals by the assessee are directed against the orders both dated 19.12.2025 of the ld. Commissioner of Income Tax (Exemption), Delhi, [hereinafter

ITA No.- 1493 and 1494/Del/2026 Society for Conservative of Nature (PRAKRITI) referred to as the ‘Ld. CIT(E)], rejecting the application for registration u/s 12AB and approval u/s 80G of the Act.

“1. On the facts and in the circumstances of the case the learned Commissioner of Income Tax (Exemptions) erred in rejecting the 80G exemption application for no solid reason. 2. The Commissioner of Income Tax (Exemptions) erred in concluding that the appellant did not comply with notices, while in fact the appellant had sought adjournments and the CIT(A) had passed rejection orders while there was still time to respond. 3. The Commissioner of Income Tax (Exemptions) failed to appreciate that the appellant had reasonable cause being it being time for filing tax returns and counsels being busy with tax audits and returns. 4. The Commissioner of Income tax (Exemptions) erred in not considering the fact that the appellant was an organization promoting science and Technology and that it had been enjoying exemption U/S 80G right from its inception in the year 1998 founded by eminent scientist and that there was never any rejection till now. 5 The commissioner of Income Tax (Exemption) erred in not considering the past record of the organization where it had been doing good work in the field of science and technology. 6. The Commissioner of Income Tax (Exemption) should have considered that the appellant organization has been doing genuine work and rejection of registration to a genuine Organisation makes it incapable of functioning and that hampers the spirit in which NGOs work. He should have noted that this rejection works against national good. 7. The above grounds are independent and without prejudice to each other 8 That the appellant craves leave to add, amend or alter any of the grounds of appeal.”

ITA No.- 1493 and 1494/Del/2026 Society for Conservative of Nature (PRAKRITI) 2.1 The assessee has raised the following grounds of appeal (ITA No.-1494 /Del/2026):

“1. On the facts and in the circumstances of the case the learned Commissioner of Income Tax (Exemptions) erred in rejecting the registration u/s12AA for no solid reason. 2. The Commissioner of Income Tax (Exemptions) erred in concluding that the appellant did not comply with notices, while in fact the appellant had sought adjournments and the CIT(A) had passed rejection orders while there was still time to respond. 3. The Commissioner of Income Tax (Exemptions) failed to appreciate that the appellant had reasonable cause being it being time for filing tax returns and counsels being busy with tax audits and returns. 4. The Commissioner of Income tax (Exemptions) erred in not considering the fact that the appellant was an organization promoting science and Technology and that it had been registered u/s 12A right from its inception in the year 1998 by eminent scientist and that there was never any rejection till now. 5. The commissioner of Income Tax (Exemption) erred in not considering the past record of the organization where it had been doing good work in the field of science and technology. 6. The Commissioner of Income Tax (Exemption) should have considered that the appellant organization has been doing genuine work and rejection of registration to a genuine Organisation makes it incapable of functioning and that hampers the spirit in which NGOs work. He should have noted that this rejection works against national good 7. The above grounds are independent and without prejudice to each other 8. That the appellant craves leave to add, amend or alter any of the grounds of appeal.” 2.2. Since common facts are involved in both the appeals, these are being disposed off vide a common order and ITA No.1494/Del/2026 w.r.t rejection of registration u/s 12AA is taken up as the lead case.

ITA No.- 1493 and 1494/Del/2026 Society for Conservative of Nature (PRAKRITI) 3. Brief facts are that the assessee filed an application for registration u/s 12A(1)(ac)(ii) is Form 10AB on 25.08.2025. A questionnaire was issued on 17.10.2025 by the CIT(E) seeking certain details/documents/clarification from the assessee. As no compliance was made by the assessee, the application for grant of registration was rejected vide order dated 19.12.2025. Aggrieved, the assessee has filed an appeal before the Tribunal. 4. Before us, none appeared on behalf of the assessee. We have heard the Ld. DR and perused the materials on record. In the interest of justice, we deem it appropriate to restore the matter to the file of Ld. CIT(E) for fresh consideration after giving reasonable opportunity of being heard to the assesse. The assessee is also directed to make requisite compliance before the CIT(E). In the result, appeal of the assessee is allowed for statistical purposes. 5. Since common facts are involved in the appeal No.1494/Del/2026 relating to rejection of approval u/s 80G, the above order shall apply mutatis mutandis to this appeal also. 6. In the result, both the appeals are allowed for statistical purposes. Order pronounced in the open court on 03.08.2026. Sd/- Sd/- [ANUBHAV SHARMA] [RENU JAUHRI] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated- 07.08.2026. Pooja/PK, Sr. PS.

ITA No.- 1493 and 1494/Del/2026 Society for Conservative of Nature (PRAKRITI)