MANJULA PRANLAL GAGLANI AND PRANLAL BHAICHAND GAGLANI PUBLIC CHARITABLE TRUST,MUMBAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), MUMBAI

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ITA 2908/MUM/2026Status: DisposedITAT Mumbai06 August 2026AY 2026-20272 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that since the approvals under Section 12AB and 80G were subsequently granted, the appeals filed against the earlier rejection orders had become infructuous.

What were the facts?

The assessee's application for renewal of registration under Section 12AB and 80G was rejected by the CIT(E) for not including a dissolution clause and violating Section 12AB(4). However, the CIT(E) subsequently granted the approvals in later orders.

What were the issues?

Whether appeals against rejection of registration under Section 12AB and 80G are maintainable when subsequent approvals are granted. The issue of non-inclusion of a dissolution clause in the trust deed.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 12AB(4),Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH; MUMBAI

Before: SHRI VIKRAM SINGH YADAV & SMT. DEBJANI MITRA NEOGY

Hearing: 03.08.2026Pronounced: 06.08.2026

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH; MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SMT. DEBJANI MITRA NEOGY, JUDICIAL MEMBER ITA Nos. 2909 & 2908/Mum/2026 (Assessment Year: 2026-27)

Manjula Pranlal Gaglani and Commissioner of Income Tax Pranlal Bhaichand Gaglani (Exemption) Public Charitable Trust vs. Cumballa Hill, MTNL Building, 13/21, 219, 2nd Floor, 3rd Mumbai, Maharashtra, 400026 Pranjrapore Lane, Mumbai, Maharashtra, 400004.

PAN: AAATM5291P (Appellant) (Respondent) For Assessee : Shri Jayendra G.Malavia For Revenue : Shri Manoj Kumar - CIT DR Date of Hearing : 03.08.2026 Date of Pronouncement : 06.08.2026 O R D E R PER VIKRAM SINGH YADAV, A.M : These are two appeals filed by the Assessee against the respective orders of the Learned Commissioner of Income Tax (Exemptions), Mumbai [‘Ld.CIT(E)’], dated 29/01/2026 wherein the assessee’s application seeking renewal of registration u/s. 12AB of the Income Tax Act, 1961 (‘the Act’) was rejected on the ground of non-inclusion of dissolution clause in trust deed/MOA and specific violation as per Explanation (g) to section 12AB(4) of the Act and consequentially, the assessee’s application u/s. 80G(5) was also rejected by separate order of even date.

ITA No. 2909 & 2908/Mum/2026; A.Y. 2026-27 Manjula Pranlal Gaglani and Pranlal Bhaichand Gaglani Public Charitable Trust 2. During the course of hearing, the ld. AR submitted that the ld. CIT(E) has since granted the approval u/s 12AB and 80G vide his separate orders dated 06.04.2026, and a copy thereof has been placed on record and it was accordingly submitted that in light of the same, the present appeals have become infructuous.

3.

After hearing both the parties and considering the fact that the ld. CIT(E) has since granted the approval u/s. 12AB and u/s 80G vide subsequent orders dated 06.04.2026, the present appeals of the assessee have become infructuous and are dismissed at the threshold.

4.

In the result, both the appeals filed by the assessee are dismissed.

Order pronounced on 06.08.2026

Sd/- Sd/- DEBJANI MITRA NEOGY VIKRAM SINGH YADAV (JUDICIAL MEMBER) (ACCOUNTANT MEMBER)

Mumbai, Dated: 06.08.2026 Karishma J. Pawar, SR. PS

Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file

By Order

Dy./Asst. Registrar I.T.A.T, Mumbai

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