What did the Tribunal hold?

The Tribunal found it appropriate to set aside the impugned order and restore the matter to the CIT(E) for fresh adjudication. The CIT(E) is to re-examine the application after considering all materials and explanations and providing an effective hearing.

The assessee's application was rejected by the CIT(Exemption). The assessee argued that their case was similar to other appeals decided similarly, where applications were rejected without proper consideration or hearing.

What were the issues?

Whether the CIT(Exemption) properly considered the assessee's explanation and afforded an effective opportunity of hearing before rejecting the application.

Zeal Educatioanal and Welfare… vs CIT | ITAT Mumbai 2026

Income Tax Appellate Tribunal, ‘D‘ BENCH

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 against the impugned order passed by the learned Commissioner of Income Tax (Exemption), Mumbai, whereby the assessee’s application has been rejected.

Before us, the learned counsel for the assessee submitted that the facts involved in the present appeal are similar to those in the batch

2 ITA No. 6204/Mum/2026 Zeal Educational and Welfare Trust

of appeals decided by us today, wherein the applications were rejected without proper consideration of the assessee’s explanation and without affording an effective opportunity of hearing. It was, therefore, prayed that the matter be restored to the file of the learned CIT(E) for fresh adjudication. The learned Departmental Representative fairly left the matter to the discretion of the Bench.

We have considered the rival submissions and perused the material available on record. Considering the facts and circumstances of the case and in the interest of substantial justice, we deem it appropriate to set aside the impugned order and restore the matter to the file of the learned CIT(E) for fresh adjudication. The learned CIT(E) shall examine the assessee’s application afresh in accordance with law after considering all the material and explanations that may be furnished by the assessee and after affording due and effective opportunity of hearing. The assessee shall also extend full cooperation in the proceedings and furnish all the requisite documents and information as may be called for.

In the result, the appeal of the assessee is allowed for statistical purposes.

Order pronounced on 10th July, 2026.

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

3 ITA No. 6204/Mum/2026 Zeal Educational and Welfare Trust

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

ZEAL EDUCATIOANAL AND WELFARE TRUST,MALAD MUMBAI vs. CIT(EXEMPTION), MUMBAI

What did the Tribunal hold?

What were the facts?

What were the issues?

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