MATRI MANDIR SAMITI,DELHI vs. INCOME TAX OFFICER, WARD EXEMPTION

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, E: NEW DELHI BEFORE SMT. KAVITHA RAJAGOPAL, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER ITA No.- 2952/Del/2026 [Assessment Year: 2021-22] Matri Mandir Samiti, Income Tax Officer, B 2, Block Safdarjung Enclave, Exemption Ward, New Delhi-110029. Vs 1(4), Civic Centre, New Delhi-110002. PAN- AABTM6433G Assessee Revenue Assessee by Shri Sanjay Jain, CA & Shri Saurabh Jain, CA Revenue by Shri Tarun Sharda, Sr. DR Date of Hearing 23.07.2026 Date of Pronouncement 07.08.2026 ORDER Per Renu Jauhri, Accountant Member:

This appeal by the assessee is directed against the order dated 09.03.2026 of the Commissioner of Income Tax, Appeal, ADDL/JCIT, (A)-12, Mumbai, [hereinafter referred to as the ‘Ld. CIT(A)] arising out of the Order dated 02.03.2023 passed under section 154 of the Income Tax Act, 1961 (hereinafter referred to as ‘the

ITA No.- 2952/Del/2026 Matri Mandir Sami� Act’) by the CPC (hereinafter referred to as the ‘AO’) pertaining to Assessment Year (A.Y.) 2021-22. 2. The assessee has raised the following grounds of appeal:

“BEFORE THE INCOМЕ ТАХ АPPEALTE TRIBUNAL, NEW DELHI IN THE MATTER OF MATRI MANDIR SAMITI AY 2021-22 ASSESSMENT U/S 143(1) GROUNDS OF APPEAL 1. The Ld. AO as well as Ld. CIT Appeal have erred in not allowing the benefit of sec 11 of the Income Tax Act by denying the utilization of Income amounting to Rs. 45,84,553.00. 2. The Ld. AO as well as Ld. CIT Appeal have erred in not appreciating that the assessee trust was registered and is registered u/s 12A/12AA/12AB, old provision and that the details have been mentioned in the form and the same cannot be ignored to deny the benefit of utilization of income. 3. That upon change of law regarding Re-registration of trust, the due date of filing application 30th June 2021 had been extended multiple time up to 30th June 2024 due to Corona Virus and due to inconvenience to the trust and under the circumstances this cannot be the reason to deny the benefit of sec 11 and the Ld. AO has erred in disallowing expenses claimed as utilization of income of the trust when all substantial provisions of the Income Tax Act 1961 have been complied with. 4. That the assessee filed a return on 14.02.2023 disclosing the New Registration No. under the new law and thus the Ld. AO has grossly erred in not passing the order in contravention law. 5. That the Ld. CIT Appeal has passed a very cryptic and non-speaking order in violation of Principle of Natural Justice and thus bad. 6. That the denial of benefit of Sec 11 and the disallowance of expenses towards utilization of Income is beyond the provisions of Sec 143(1)(a) and its other provisions and thus the Intimation Order Income Tax Act u/s 143(1) is bad and opposed to law. 7. Without Prejudice to the above, even if the trust is not registered u/s 11, the assessment can not be made on its gross income without allowing for the expenses incurred against such income. 8. That the assessment order is bad in law and facts of the case. 9. That the above grounds of appeal are without prejudice to one another 10. That your Appellate Prays that he be allowed to add, amend or forgo any of the above Grounds of Appeal at the time of hearing of appeal.”

ITA No.- 2952/Del/2026 Matri Mandir Sami� After the introduction of new regime for registration and re-registration of the trusts, it applied for and was granted provisional registration on 31.05.2021 for A.Y. 2022- 23 to A.Y. 2024-25. Meanwhile, the assessee had filed his return for A.Y. 2021-22 on 12.03.2022 claiming exemption u/s 11 of the Act. The return was processed u/s 143(1) and claim of exemption was derived by the CPC on the ground that new registration details were not available.

Aggrieved, the assessee filed an application for rectification u/s 154 before the CPC, which was also rejected vide order dated 2.3.2023.

3.1 The assessee preferred an appeal before the CIT(A) against this order. However, the CIT(A) rejected the appeal on the ground that there was no infirmity in the order u/s 154 of the Act.

Further aggrieved, the assessee has filed the present appeal before the Tribunal.

ITA No.- 2952/Del/2026 Matri Mandir Sami� which was duly granted and therefore the CPC without giving the assessee any opportunity, proceeded to reject the claim of exemption on the ground that details of registration under the new regime were not available. Ld. AR has placed reliance on the decision of the coordinate bench of Chennai, in the case of ITO vs. The Christian Businessmen Education Fellowship, ITA No. 2395/CHNY/2025, dated 19.01.2026, wherein it has been held that disallowance of entire expenditure by rejecting the claim of exemption u/s 11 by the CPC is not justified in processing under section 143(1)(a) and that the same is not sustainable.

ITA No.- 2952/Del/2026 Matri Mandir Sami� 7. In the result, appeal of the assessee is allowed.

Order pronounced in the open court on 07.08.2026

Sd/- Sd/- [KAVITHA RAJAGOPAL] [RENU JAUHRI] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated- 07.08.2026. Pooja, Sr. PS. Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) 5. DR

Asst. Registrar, ITAT, New Delhi,