SARDAR CHETAN SINGH CHARITABLE TRUST,LUDHIANA vs. CIT EXEMPTIONS CHANDIGARH, CHANDIGARH

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ITA 1880/CHANDI/2025Status: DisposedITAT Chandigarh06 August 2026AY 2025-263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal accepted the assessee's prayer to remand the matter back to the CIT(E) for fresh consideration, citing principles of natural justice. The assessee was directed to present its case and provide necessary documentation.

What were the facts?

The assessee's application for registration under Section 12A(1)(ac)(ii) was rejected by the CIT(E) because the purpose and justification for purchasing units in a business park were not disclosed, and supporting documents were not provided. The assessee claimed the credits were refunds from the seller upon cancellation of a unit.

What were the issues?

Whether the rejection of the registration application was justified without providing an opportunity for hearing and considering additional evidence. The transparency of financial transactions with the vendor was also a concern.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, CHANDIGARH

Before: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM & HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, CHANDIGARH VIRTUAL HEARING BEFORE HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI RAJESH DAMODARLAL SHARMA, JM आयकरअपीलसं. / ITA No.1880/CHANDI/2025 Sardar Chetan Singh Charitable CIT (Exemptions) Trust Room No.1, 5th Floor, C R Building बनाम/ B-I-1362, Opp. Old Distt Courts Himalaya Marg, Sector – 17E Beri Road, Rattan Building Chandigarh – 160017 Vs. Civil Lines Ludhiana Punjab – 141001 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AAATS-4080-J (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Pankaj Bhalla (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Jaishree Sharma (CIT) - Ld. DR सुनवाईकीतारीख/Date of Hearing : 05-08-2026 घोषणाकीतारीख /Date of Pronouncement 06-08-2026 : आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by rejection of an application as filed by the assessee seeking registration u/s 12A(1)(ac)(ii) vide impugned order dated 03.12.2025 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeal before us. 2. Upon perusal of Para 4.1 of impugned order, it could be seen that the registration has been denied on the ground that the assessee purchased units in a Vipul Business Park from Vipul Private Limited

but the assessee did not disclose the purpose or justification for such purchase or how such an acquisition was connected with its stated charitable objects. The assessee merely stated that the credits represent refunds received from Vipul Private Limited against cancellation of a unit in the Vipul business Park. However, the assessee failed to furnish the supporting documentary evidences such as allotment letter, agreement to purchase and payment receipt for alleged purchase. The financial transactions with Vipul Private Limited lacked transparency. Accordingly, the application was rejected. 3. The Ld. AR stated that no opportunity of hearing was granted to the assessee before forming such an opinion. The Ld. AR also filed additional evidence u/r 29 of ITAT Rules, 1963 and stated that the same would meet the objections of Ld. CIT (E). Accordingly, a prayer has been made to remand back the matter which has been opposed by Ld. CIT-DR. 4. Keeping in mind the principles of natural justice, we accept the prayer of Ld. AR. Hence, we set aside the impugned order and restore the registration application back to Ld. CIT(E) for fresh consideration in the light of above submissions of Ld. AR. The assessee is directed to plead and its case forthwith. 5. The appeal stand allowed for statistical purposes. Order pronounced on 06th August, 2026

-Sd- -Sd- (RAJESH DAMODARLAL SHARMA) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER

AS Dated: 06-08-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

ASSISTANT REGISTRAR

ITAT CHANDIGARH

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