SHIKSHAN PRASARAK MANDAL,DAHANU vs. INCOME TAX OFFICER EXEMPTION , THANE

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ITA 5809/MUM/2026Status: DisposedITAT Mumbai10 July 2026AY 2026-274 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that a fresh order was passed granting regular registration to the assessee, superseding the earlier rejection order. Therefore, the appeal became infructuous.

What were the facts?

The assessee-trust's application for regular registration under section 12A(1)(ac)(iii) was rejected because its provisional registration was cancelled. Subsequently, the ITAT restored the matter for fresh adjudication.

What were the issues?

Whether the appeal challenging the rejection of registration is maintainable when the registration has been subsequently granted.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D‘ BENCH

For Appellant: Shri. Rahul Hakani
For Respondent: Shri. Azhar Kabir, Sr. DR
Hearing: 10/07/2026Pronounced: 10/07/2026

आदेश / O R D E R PER AMIT SHUKLA (J.M): This appeal has been filed by the assessee-trust against the order dated 19.03.2026 passed by the Ld. Commissioner of Income Tax (Exemption), Pune, rejecting the assessee’s application for grant of regular registration under section 12A(1)(ac)(iii) of the Income-tax Act, 1961. The rejection was primarily founded on the ground that the provisional

2 ITA No. 5809/Mum/2026 Shikshan Prasarak Mandal

registration earlier granted to the assessee had already been cancelled and, therefore, according to the Ld. CIT(E), the statutory pre-condition for grant of regular registration under section 12A(1)(ac)(iii) was not fulfilled.

2.

At the time of hearing, the Ld. Counsel for the assessee submitted that subsequent to the impugned order, the very basis on which the present appeal had been filed no longer survives. It was pointed out that pursuant to the directions of the Hon’ble ITAT, Pune Bench, contained in its order dated 05.01.2026, whereby the matter had been restored to the file of the Ld. CIT(E) for fresh adjudication, the Ld. CIT(E), after examining the documents and affording due opportunity to the assessee, has passed a fresh order dated 24.04.2026 granting regular registration under section 12A(1)(ac)(iii) of the Act for the assessment years 2023-24 to 2027-28. A copy of the said registration order has been placed before us.

3.

The Ld. Departmental Representative fairly did not dispute the aforesaid factual position.

4.

We have heard the rival submissions and perused the material placed on record. It is an undisputed position that the impugned order dated 19.03.2026 rejecting the application for registration has subsequently been superseded by the fresh order passed by the Ld. CIT(E) on 24.04.2026,

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whereby the assessee has been granted regular registration under section 12A(1)(ac)(iii) of the Act in compliance with the directions of the Hon’ble ITAT, Pune Bench. Thus, the grievance raised in the present appeal stands fully redressed and no surviving cause of action remains for adjudication before us. Once the substantive relief sought by the assessee has already been granted by the competent authority, adjudication on the validity of the earlier rejection order would be merely academic and would serve no useful purpose.

5.

Accordingly, the present appeal is dismissed as having become infructuous, with liberty to the assessee to seek appropriate remedy in accordance with law, if the need so arises in future.

6.

In the result, the appeal filed by the assessee is dismissed as infructuous.

Order pronounced on 10th July, 2026.

Sd/- Sd/- (ARUN KHODPIA) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 10/07/2026 KARUNA, sr.ps

4 ITA No. 5809/Mum/2026 Shikshan Prasarak Mandal

Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// BY ORDER,

(Asstt. Registrar) ITAT, Mumbai

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