SRI HANUMAN MANDIR SATSANG MANDAL TRUST,PATIALA vs. CIT-EXEMPTIONS, CHANDIGARH, CHANDIGARH
What did the Tribunal hold?
The Tribunal found merit in the assessee's contention that a comprehensive examination was required and that principles of natural justice were violated. The assessee was not afforded a sufficient and effective opportunity of hearing.
What were the facts?
The assessee appealed an order by the CIT (Exemptions) for AY 2026-27. The assessee contended that it was not given a proper opportunity to explain its activities and claims before the CIT.
What were the issues?
Whether the CIT (Exemptions) order was passed in violation of the principles of natural justice due to insufficient opportunity of hearing granted to the assessee.
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DIVISION BENCH, ‘B’ CHANDIGARH
Before: SHRI LALIET KUMAR & SHRI MANOJ KUMAR AGGARWAL
आयकर अपील�य अ�धकरण,च�डीगढ़ �यायपीठ, च�डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘B’ CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER AND SHRI MANOJ KUMAR AGGARWAL, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 855/CHD/2026 �नधा�रण वष� / Assessment Year: 2026-27 Sri Hanuman Mandir Satsang Mandal Trust, The CIT (Exemptions), Near Bir Dasondhi Ram Apahaj Ashram, V Chandigarh. Rajpura Road, Patiala. s �थायी लेखा सं./PAN NO: AANTS5275 अपीलाथ�/Appellant ��यथ�/Respondent Assessee by : Shri Deepak Aggarwal, Advocate Revenue by : Smt. Kusum Bansal, Pr.CIT, DR Date of Hearing : 15.07.2026 Date of Pronouncement : 20.07.2026 HYBRID HEARING O R D E R PER LALIET KUMAR, JM
The present appeal has been preferred by the assessee against the order passed by the Ld. Commissioner of Income Tax (Exemptions), Chandigarh dated 12.02.2026 for the Assessment Year 2026-27.
The Ld. Authorised Representative (AR) submitted that the impugned order passed by the Ld. CIT (Exemptions) suffers from violation of the principles of natural justice. It was contended that though notices were issued, no effective and meaningful
ITA No.855/CHD/2026 2
opportunity was afforded to the assessee society to explain the nature of its activities and to place on record the relevant material in support of its claim. It was further submitted that the representatives of the assessee could not properly explain the factual and legal aspects before the Ld. CIT (Exemptions), which resulted in an adverse order without proper appreciation of the objects and activities of the assessee. It was, therefore, prayed that the matter be restored to the file of the Ld. CIT (Exemptions) for fresh adjudication after granting adequate opportunity of hearing.
The Ld. Departmental Representative (DR), on the other hand, relied upon the findings recorded in the impugned order. It was submitted that sufficient opportunities had been granted to the assessee during the course of proceedings.
We have heard the rival submissions and perused the material available on record. We find merit in the contention of the assessee that the issues involved require a comprehensive examination by the Ld. CIT (Exemptions). From the record, it appears that the assessee could not effectively explain its case before the Ld. CIT (Exemptions), and the impugned order has been passed without affording a sufficient and effective opportunity of hearing to the assessee. In our considered opinion, the principles of natural justice require that the assessee be granted one effective opportunity to substantiate its claim before any adverse decision
ITA No.855/CHD/2026 3
is taken.
Accordingly, the impugned order passed by the Ld. CIT (Exemptions) in the present appeal is set aside and the matter is restored to his file for adjudication afresh in accordance with law after providing adequate and effective opportunity of hearing to the assessee. The assessee shall also extend full cooperation and furnish all relevant documents and explanations as may be called for by the Ld. CIT (Exemptions). The Ld. CIT (Exemptions) shall pass a reasoned and speaking order, dealing with each of the contentions raised by the assessee, in accordance with law.
Accordingly, the appeal is allowed for statistical purposes.
Order pronounced on 20 t h July,2026.
Sd/- Sd/-
(MANOJ KUMAR AGGARWAL) (LALIET KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER “Poonam” आदेश क� �ितिलिप अ�ेिषत/ Copy of the order forwarded to : अपीलाथ�/ The Appellant 1. ��यथ�/ The Respondent 2. आयकर आयु�/ CIT 3. िवभागीय �ितिनिध, आयकर अपीलीय आिधकरण, च�डीगढ़/ DR, ITAT, CHANDIGARH 4. गाड� फाईल/ Guard File 5.
सहायक पंजीकार/ Assistant Registrar
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