AMBIGAI NARAYANAN EDUCATIONAL TRUST,THANJAVUR vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHENNAI

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ITA 1919/CHNY/2026Status: DisposedITAT Chennai05 August 2026AY 2026-20274 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the CIT(E)'s orders and restored the matter to his file, providing the assessee one more opportunity to substantiate its claim with the submitted documents.

What were the facts?

The assessee filed applications for registration u/s.12AB and approval u/s.80G. The CIT(E) rejected these applications for non-compliance and failure to furnish mandatory documents.

What were the issues?

Whether the rejection of applications for registration and approval due to non-submission of documents was justified, and if a further opportunity should be granted.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & MS PADMAVATHY S

Hearing: 03.08.2026Pronounced: 05.08.2026

आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT:

These two appeals filed by the assessee are directed against two orders of the Commissioner of Income Tax (Exemption), Chennai both dated 21.03.2026, rejecting Form No.10AB filed for seeking registration u/s.12AB and approval u/s.80G of the Income Tax Act, 1961 (hereinafter the ‘Act’).

- 2 - ITA No.1919 & 1920/CHNY/2026 Ambigai Narayanan Educational Trust 2. At the very outset, we notice that the CIT(E) has rejected the applications filed by the assessee seeking registration u/s.12AB of the Act and approval u/s.80G of the Act, by holding that the assessee has failed to comply with the notices and has not furnished all the mandatory documents required for examining the objects and genuineness of the activities.

3.

Aggrieved by the order of CIT(E) rejecting the assessee’s application for registration u/s.12AB of the Act and approval u/s.80G of the Act, the assessee has filed the present appeals before the Tribunal. Before us, none appeared on behalf of the assessee. However, it is stated in the statement of facts and in grounds of appeal, that the CIT(E) had rejected the applications filed by the assessee for non-submission of mandatory documents. Before the Tribunal, the assessee has filed the requisite documents in support of its claim.

4.

We have heard the Ld. DR and perused the material available on record. The impugned orders reveal that the CIT(E) rejected the assessee's applications for registration u/s.12AB of the Act and approval u/s. 80G of the Act on the ground that the assessee had failed to furnish the requisite documents called for

- 3 - ITA No.1919 & 1920/CHNY/2026 Ambigai Narayanan Educational Trust during the proceedings. Though none appeared on behalf of the assessee before us, the assessee has filed before the Tribunal the relevant documents in support of its claim and has contended in the statement of facts and the grounds of appeal that the applications came to be rejected only for want of submission of such documents. Considering the facts and circumstances of the case, we are of the view that the applications have been rightly rejected by the CIT(E). However, in the interest of justice and equity, we are of the view that assessee ought to be provided with one more opportunity to substantiate its claim. Accordingly, without expressing any opinion on the merits of the applications, we set aside the impugned orders of the CIT(E) and restore the matter to his file with a direction to consider the applications for registration u/s.12AB and approval u/s. 80G of the Act afresh. The CIT(E) is directed to examine the documents and evidences to be furnished by the assessee and shall afford a reasonable opportunity of being heard. The assessee is directed to extend full co-operation, furnish all the requisite details and evidences as may be called for by the CIT(E), and shall not seek unnecessary adjournments. It is ordered accordingly.

- 4 - ITA No.1919 & 1920/CHNY/2026 Ambigai Narayanan Educational Trust 5. In the result, both the appeals filed by the assessee are allowed for statistical purposes.

Order pronounced in the open court on 5th August, 2026 at Chennai.

Sd/- Sd/- (जॉज� जॉज� के) (प�मावती एस) (PADMAVATHY S) (GEORGE GEORGE K) लेखा सद�य/ACCOUNTANT MEMBER उपा�य� /VICE PRESIDENT चे�नई/Chennai, �दनांक/Dated, the 5th August, 2026 RSR, Sr.PS आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��यथ�/Respondent 3. आयकर आयु�त /CIT, Madurai 4. �वभागीय ��त�न�ध/DR 5. गाड� फाईल/GF. By Order Digitally signed by REKHA REKHA SENTHIL RAJ SENTHIL RAJ Date: 2026.08.06 15:44:18 +05'30'

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