SHREE GOPILAL MOHINIDEVI MANGLUNIA CHARITABLE TRUST,MUMBAI vs. CIT EXEMPTION MUMBAI, MUMBAI

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ITA 2958/MUM/2026Status: DisposedITAT Mumbai13 July 2026AY 2026-273 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal restored both appeals to the file of the CIT(E) to reconsider the matter. The CIT(E) was directed to provide a fair opportunity to the assessee, and the assessee was directed to furnish required details in time.

What were the facts?

The assessee trust applied for registration under section 12AB and approval under section 80G. The CIT(E) rejected both applications for want of compliance with a show cause notice. The assessee sought one more opportunity to contest the case on merit.

What were the issues?

Whether the rejection of registration and approval due to non-compliance with a show cause notice was justified, and if the assessee should be granted another opportunity to present its case.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

PER PAWAN SINGH, JUDICIAL MEMBER: 1. These two appeals by assessee are directed against the separate orders of ld. CIT(E) both dated 27.02.2026 in rejecting the registration of trust under section 12AB and approval of fund under section 80G. Facts in both the years are interconnected; therefore, both the appeals are taken together for hearing. 2. Rival submissions of both the parties have been heard and record perused. The learned Authorised Representative (ld. AR) of the assessee submits that ld. CIT(A) issued show cause notice for seeking certain details on the object

Shree Gopilal Mohinidevi Manglunia Charitable Trust ITA Nos. 2958 & 2959/Mum/2026 (AY: 2026-27)

and activities of the assessee vide notice dated 11.01.2026 to furnish submission within a week. The assessee could not furnish such submission. Resultantly, both the applications of assessee were dismissed for the want of compliance for verification of object and activities. The ld. AR of the assessee submits that he may be allowed one more opportunity to contest the case on merit. He undertakes on behalf of the assessee to be more vigilant in future in making timely compliance. 3. On the other hand, the learned Commissioner of Income Tax – Departmental Representative (ld. CIT-DR) for the Revenue submits that assessee was given opportunity to file reply but the assessee failed to respond such notices. 4. We have considered the rival submissions of both the parties and find that both the applications of assessee registration of trust under section 12AB and approval of fund under section 80G(5) was rejected for the want of compliance. Before us, the ld. AR of the assessee has undertaken to be more vigilant in future in making timely compliance, therefore, we deem it appropriate to restore both the appeal to the file of ld. CIT(A) to reconsider the matter and passed the order in accordance with law. Needless to direct that the ld. CIT(E) shall allow fairly and reasonable opportunity to the assessee before passing the order afresh. The assessee is also directed to furnish required details in time.

Shree Gopilal Mohinidevi Manglunia Charitable Trust ITA Nos. 2958 & 2959/Mum/2026 (AY: 2026-27)

5.

In the result, both the appeals of the assessee areallowed for statistical purpose. Order was pronounced in the open Court on13/07/2026 at the time of hearing.

/- S/- Sd/- /- Sd/- Sd/- OM PRAKASH KANT PAWAN SINGH ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai, Dated: 13/07/2026 Biswajit Copy of the order forwarded to: (1) The Assessee; (2) The Revenue; (3) The PCIT / CIT (Judicial); (4) The DR, ITAT, Mumbai; and (5) Guard file. By Order

Assistant Registrar ITAT, Mumbai

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