SRI SAT SAHIB EDUCATION SOCIETY,KARNAL, HARYANA vs. CIT EXEMPTIONS, CHANDIGARH

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ITA 854/CHANDI/2026Status: DisposedITAT Chandigarh20 July 2026AY 2027-283 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the impugned orders, directing the CIT(E) to re-adjudicate the application dated 30-09-2025 on its merits. The earlier withdrawn application was to be treated as such.

What were the facts?

The assessee filed an application for registration on 29-09-2025, which was later withdrawn. A fresh application was filed on 30-09-2025. However, the impugned orders rejected the first application on merits and treated the second as a duplicate.

What were the issues?

Whether the CIT(E) correctly rejected the assessee's application for registration by treating a subsequent valid application as a duplicate and not considering the withdrawn application appropriately.

Which sections of the Income-tax Act were involved?

Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Heard together (2 matters)

ITA No.853/CHANDI/2026
ITA No.854/CHANDI/2026

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI LALIET KUMAR, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकर अपील सं./ ITA No.853/CHANDI/2026 & 2. आयकर अपील सं./ ITA No.854/CHANDI/2026 Sri Sat Sahib Education Society CIT (Exemptions) 1/535, Adarsh Public School CR Building, Himalaya Marg बनाम/ Vs. Kunjpura Road, Sector – 1 Sector – 17E, Chandigarh TP Scheme, Karnal – 132001 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AABAS-3889-F (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Ashok Goyal (CA) & Sh. Tarun Jindal (CA) – Ld. ARs ��थ�कीओरसे/Respondent by : Smt. Kusum Bansal (Pr. CIT) - Ld. DR (Virtual) सुनवाईकीतारीख/Date of Hearing : 15-07-2026 घोषणाकीतारीख /Date of Pronouncement 20-07-2026 : 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 12AB(1)(b)(ii) vide impugned orders dated 27- 02-2026 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeals before us. The Ld. AR pointed out that the application as filed by the assessee

on 29-09-2025 was withdrawn by the assessee and another application was filed on 30-09-2025. However, the impugned orders have rejected assessee’s application dated 29-09-2025 on merits and held the application filed on 30-09-2025 as duplicate one. The Ld. AR stated that only valid application which is to be considered is assessee’s application dated 30-09-2025. The Ld. CIT-DR fairly stated that the matter may be remanded back to the registering authority for re-adjudication. 2. We find that in ITA No.853/Chandi/2026, the assessee is aggrieved by rejection of its application dated 29-09-2025. However, this application was withdrawn by the assessee. Subsequently, another application was preferred on 30-09-2025 which is to be adjudicated afresh on merits whereas this application has been rejected as duplicate application. On these facts, we set aside the impugned orders and direct Ld. CIT(E) for de novo consideration of assessee’s application dated 30-09-2025 on merits. The assessee is directed to plead and prove its case forthwith. As per extant statutory provisions, while considering registration application, the Ld. CIT(A) is required to satisfy itself about genuineness of assessee’s activities and also ensure compliance with such other laws which are material for achieving the stated objects. These parameters are to be broadly considered during set aside proceedings. The application dated 29- 09-2025 has already been withdrawn by the assessee. The same my accordingly be treated by Ld. CIT(E) as withdrawn application.

3.

Both the appeals stand allowed for statistical purposes. Order pronounced on 20th July, 2026

-Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 20-07-2026 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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