UDUMALPET TEJAS ROTARY TRUST,UDUMALPET vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHENNAI

आयकर अपीलीय अधिकरण ‘सी’ न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI माननीय श्री एबी टी. वर्की, न्याययक सदस्य एवं श्री गगन गोयल लेखा सदस्य के समक्ष BEFORE HONOURABLE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 2198 & 2199/Chny/2026 ननिाारण वर्ा /Assessment Years: - Udumalpet Tejas Rotary Trust, v. The Commissioner of Income No.24, Andal Srinivasan Layout, Tax (Exemptions), Udumalpet, Tiruppur, Chennai. Tamil Nadu-642 126. [PAN: AAATU6590K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee by : Ms. Sandhya, C.A, Ld. AR प्रत्यर्थी की ओर से /Revenue by : Mr.Chilaka Marthi Vijay Raju, Addl. CIT, Ld. DR सुनवाईकीतारीख/Date of Hearing : 17.06.2026 घोषणाकीतारीख /Date of Pronouncement : 20.07.2026 आदेश / O R D E R PER GAGAN GOYAL, AM: These two appeals are preferred by the assessee against the order of the Ld. Commissioner of Income Tax (Exemption) (hereinafter referred as the ‘Ld. CIT (E)), Chennai dated 18.03.2026.

GROUNDS OF APPEAL 1. The order passed by the learned CIT (Exemptions) is bad in law and liable to be set aside. 2. The learned CIT (Exemptions) erred in holding that the Appellant failed to submit required documents, which is factually incorrect and he failed to consider the detailed replies and documents already on record. The said replies and other enclosures were uploaded within the time. 3. The learned CIT (Exemptions) erred in rejecting the application without adjudicating the delay condonation petition. The delay was due to genuine and Bonafide reasons supported by documentary evidence.

Page 1 of 3

ITA No.2198 & 2199/Chny/2026 (-) Udumalpet Tejas Rotary Trust 4. The learned CIT (Exemptions) failed to appreciate that the Appellant already holds provisional registration (Form 10AC) and applied for regular registration in Form 10AB. 5. The learned CIT (Exemptions) erred in insisting upon submission of old 12A / 12AA registration, which is not applicable. The rejection based on a non-applicable condition is arbitrary and bad in law. The impugned order is in violation of principles of natural justice. The order is mechanical and passed without application of mind. 6. The Appellant craves leave to add, alter, amend or withdraw any of the above grounds at or before the time of hearing. 7. In view of the facts and settled law, the appellant respectfully prays that the Hon'ble Tribunal may set aside the order of CIT Appeals and order to grant permanent registration. 2. The brief facts of the case are that the assessee is a trust applied in Form No.10AB on 01.08.2025 seeking registration u/s. 12AB of the Act. But the same was rejected by the Ld. CIT (E), Chennai vide order dated 18.03.2026. The assessee being aggrieved by this order preferred the present appeal before us. We have gone through the order of the Ld. CIT (E), Chennai and the submissions of the assessee along with the grounds taken before us.

i) Trust deed / MOA / Instrument creating or establishing the institution. ii) Financials for the previous three years & Note on activities. iii) Copy of approval u/s. 12A / 12AA obtained in the old regime i.e. prior to 01.04.2021. 4. However, it is observed that the assessee has already furnished the above information before the Ld. CIT (E), Chennai vide evidences of furnishing the same submitted before us vide page nos. 23 to 461 of the paper book. Moreover, the issue of delay was not at all discussed by the Ld. CIT (E), Chennai in his order dated 18.03.2026, hence it is assumed in favour of the assessee that the same has been condoned by the Ld. CIT (E), Chennai.

Page 2 of 3

ITA No.2198 & 2199/Chny/2026 (-) Udumalpet Tejas Rotary Trust question of delay in applying, after giving a proper opportunity of being heard to the assessee. In the result, the grounds raised by the assessee in ITA Nos. 2198 and 2199 / Chny / 2026 are allowed for statistical purposes. 6. In the result, both the appeals of the assessee are allowed for statistical purposes in view of above observations and findings. Order pronounced on the 20th day of July, 2026, in Chennai.

Sd/- Sd/- (एबी टी. वर्की) (गगन गोयल) (ABY T. VARKEY) (GAGAN GOYAL) न्याययक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER चेन्नई/Chennai, ददनाांक/Dated: 20th July, 2026. KB आदेश की प्रयतललपप अग्रेपषत/Copy to: 1. अपीलार्थी/Appellant 2. प्रत्यर्थी/Respondent 3. आयकर आयुक्त/CIT, Chennai /Madurai/Coimbatore/Salem 4. पवभागीय प्रयतयनधि/DR Digitally signed by 5. गार्ड फाईल/GF K BABU K BABU Date: 2026.07.27 11:47:19 +05'30'

Page 3 of 3