ZIGAR BUDDHIST BODHGAYA TRUST,GAYA vs. ITO EXEMPTION, WARD-1, PATNA

ITA 63/PAT/2026Status: DisposedITAT Patna20 July 2026AY 2025-265 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeals. It held that the cancellation of provisional registration and approval by the CIT(E) was done without granting a proper opportunity to the assessee. Therefore, the matter was remitted back to the CIT(E) for fresh consideration.

What were the facts?

The assessee's appeals were delayed by 175 days. The assessee sought condonation of delay, citing lack of legal awareness. The appeals were for cancellation of provisional registration under Section 12A(1)(ac)(vi) and approval under Section 80G(5)(iv) due to non-compliance with notices.

What were the issues?

Whether the delay in filing the appeal should be condoned and whether the CIT(E) properly afforded an opportunity of being heard before cancelling the provisional registration and approval.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(vi),Section 80G(5)(iv),Section 253(5),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

For Appellant: Shri Subhash Agarwal, AR
For Respondent: Shri Bharat Bhusan Garg, CIT-DR
Hearing: 01.07.2026Pronounced: 20.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

These two appeals filed by the assessee against the orders passed the Ld. Commissioner of Income Tax (Exemption), Patna [hereinafter referred to as “the Ld. CIT(E)] dated 23.05.2025, DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/1076396777(1) and ITBA/EXM/F/EXM45/2025-26/1076397127(1) for AY 2025-26 respectively for not granting registration u/s 12A(1)(ac)(vi) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) and not granting registration u/s 80G(5)(iv) of the Act. Since the issues involved are

The order continues below.

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