ERODE SAI EDUCATIONAL TRUST,ERODE vs. CIT EXEMPTIONS, CHENNAI

आदेश / O R D E R

PER MANU KUMAR GIRI, JM:

These two appeals by the assessee arise out of the separate orders of the ld. Commissioner of Income-tax (Exemptions) [CIT(E)] both dated 16.03.2026, whereby the applications filed by the assessee in Form No. 10AB seeking registration u/s. 12AB and approval u/s. 80G of the Income Tax Act, 1961 were rejected. 2. We have heard the rival submissions and perused the material available on record. The assessee had filed applications in Form No. 10AB on 30.09.2025 seeking registration u/s. 12AB as well as

ITA No 3187 & 3188/Chny/2026 (A Y) Erode Sai Educational Trust Vs CIT E :: 2 :: approval u/s. 80G of the Act. The ld. CIT(E) observed that certain documents, namely the trust deed/MOA/instrument creating the institution, financial statements along with a note on activities and, in the case of registration u/s. 12AB, copy of the earlier approval u/s. 12A/12AA, were required for examining the objects of the trust and the genuineness of its activities. Since, according to the ld.CIT(E), the assessee did not comply with the notices issued and failed to furnish the requisite documents, both the applications came to be rejected. 3. From a perusal of the impugned orders, we find that the ld. CIT(E) has rejected the applications primarily on the ground of non- compliance with the notices issued and non-furnishing of the documents considered necessary for examination of the applications. No finding has been recorded on the merits of the objects of the trust or the genuineness of its activities after examining the relevant materials. The rejection is thus founded solely on the alleged non-compliance. 4. In our considered opinion, the issue involved relates to grant of registration u/s. 12AB and approval u/s. 80G, which have significant civil consequences for the assessee. Therefore, before rejecting such applications, the authority is expected to afford an effective and meaningful opportunity to the applicant/assessee to furnish the requisite documents and explain its case. The principles of natural justice require that adequate opportunity be granted before an adverse order is passed. 5. Considering the facts and circumstances of the case, we are of the view that the ends of justice would be met if the impugned orders are set aside and the matters are restored to the file of the ld. CIT(E) for fresh adjudication. Accordingly, both the impugned

ITA No 3187 & 3188/Chny/2026 (A Y) Erode Sai Educational Trust Vs CIT E :: 3 :: orders dated 16.03.2026 passed u/s. 12AB and section 80G are hereby set aside. The ld. CIT(E) shall re-examine the applications afresh in accordance with law after providing adequate and effective opportunity of hearing to the assessee. The assessee shall also extend full cooperation by furnishing all the documents, information and explanations that may be called for by the ld. CIT(E) without seeking unnecessary adjournments. 6. We clarify that we have not expressed any opinion on the merits of the assessee's entitlement to registration u/s. 12AB or approval u/s. 80G. All issues are left open for consideration by the ld. CIT(E) in accordance with law. 7. In the result, both the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on the 05th day of August 2026 in Chennai.

Sd/- Sd/- (गगन गोयल) (मनु कुमार िग�र) (Gagan Goyal) (MANU KUMAR GIRI) लेखा सद)य/ACCOUNTANT MEMBER �या�यक सद)य/JUDICIAL MEMBER चे�नई/Chennai, Digitally signed SANDEE *दनांक/Dated: 05th August, 2026. by SANDEEP SNDP, Sr. PS KUMAR P KUMAR Date: 2026.08.11 आदेश क ��त+ल,प अ-े,षत/Copy to: 1. अपीलाथ�/Appellant 17:51:04 +05'30' 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF