BELDHI BAPTIST CHURCH SOCIETY,JAMSHEDPUR vs. COMMISSIONER OF INCOME TAX, PATNA, PATNA

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ITA 238/RAN/2026Status: DisposedITAT Ranchi30 July 2026AY 2025-263 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal restored the issue to the file of the CIT(Exemption) for readjudication. The application is to be treated as an application for extension of registration, considering the registration already granted.

What were the facts?

The assessee society applied for registration under section 12AB of the Income Tax Act. The CIT(Exemption) rejected the application because the assessee did not possess registration under section 12A/12AA prior to April 1, 2021.

What were the issues?

Whether the CIT(Exemption) erred in rejecting the application for registration under section 12AB solely on the ground of lacking prior 12A/12AA registration, when the assessee sought fresh registration or extension.

Which sections of the Income-tax Act were involved?

Section 12A,Section 12AA,Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: S/SHRI GEORGE MATHAN & RATNESH NANDAN SAHAY

For Appellant: Shri Akshay Ringasia, AR
For Respondent: Shri H. Rovindro Singh, ld CIT DR
Hearing: 30/07/2026Pronounced: 30/07/2026

IN THE INCOME TAX APPELLATE TRIBUNAL, RANCHI BENCH, RANCHI BEFORE S/SHRI GEORGE MATHAN, JUDICIAL MEMBER AND RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No. 238/RAN/2026 Assessment Year: 2025-26 Beldih Baptist Church Vs. CIT, Patna Society, Beldih Trinagle, Jamshedpur – 831001, East Singhbhum, Jharkhand. PAN/GIR No. AAGAB5247D (Appellant) .. ( Respondent)

Assessee by : Shri Akshay Ringasia, AR Revenue by : Shri H. Rovindro Singh, ld CIT DR Date of Hearing : 30/07/2026 Date of Pronouncement : 30/07/2026

O R D E R Per Bench This is an appeal filed by the assessee against the order of the ld CIT Exemption, Patna, dated 18.03.2026 rejecting the assessee’s claim of registration u/s.12A(1) of the Act, in Appeal No. CIT Exemption, Patna/2025-26/12AA/14093 for the assessment year 2025-26.

2.

Shri Akshay Ringasia, ld AR appeared for the assessee and Shri H.Robindro Singh, ld CIT DR appeared for the revenue.

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ITA No. 238/RAN/2026 Assessment Year: 2025-26

2.

It was submitted by ld AR that the ld CIT (Exemption) has rejected the application filed in Form No.10AB seeking approval under section 12AB of the Act on the ground that the assessee has not provided the copy of the registration u/s.12A/12AA of the Act prior to 1.4.2021. It was the submission that it was responded to the ld CIT (Exemption) that the society did not have registration under section 12A/12AA of the Act prior to 1.4.2021. It was the submission that the assessee had asked for registration u/s.12A/12AA as per the provisions of section 12AA(ac)(ii) of the Act. It was the submission that the assessee has applied for extention of registration and not as old trust. It was the prayer that the issue may be restored to the file of the ld CIT(Exemption) for readjudication after granting the assessee adequate opportunity of hearing.

3.

Ld CIT DR did not have serious objection to the request of ld AR of the assessee.

4.

We have considered the rival submissions. As it is noticed that the assessee does not have registration u/s.12A/12AA prior to 1.4.2021 and the assessee has also categorically admitted that it has applied for fresh registration and it is noticed that the ld CIT(Exemption) has rejected the application of the assessee only on the ground that the assessee did not have old registration prior to 1.4.2021, the issues in this appeal are restored to the file of the ld CIT(E) for readjudication by treating the application filed by the assessee as application for extention of registration u/s.123A/12AA of the Act to the registration already granted vide order dated

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ITA No. 238/RAN/2026 Assessment Year: 2025-26

7.4.2022 from the assessment year 2022-23 to 2026-27. With these directions, the appeal is restored to the file of the ld CIT(Exemption).

5.. In the result, appeal of the assessee stands partly allowed for statistical purposes.

Order dictated and pronounced in the open court on 30/07/2026.

Sd/- sd/- (RATNESH NANDAN SAHAY) (GEORGE MATHAN) ACCOUNTANT MEMBER JUDICIAL MEMBER Ranchi; Dated 30/07/2026 Amit (Sr.PS) Copy of the Order forwarded to : 1. The Appellant : Beldih Baptist Church Society, Beldih Trinagle, Jamshedpur – 831001, East Singhbhum, Jharkhand. 2. The Respondent: CIT, Patna 3. The CIT(A)-Patna 4. Pr.CIT, Ranchi 5. DR, ITAT, 6. Guard file. By order //True Copy//

Sr.Pvt. Secretary ITAT, Ranchi

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