SRI MAHARAJAPURAM SANTHANAM RASIKAS TRUST,CHENNAI vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHENNAI
What did the Tribunal hold?
The Tribunal allowed the appeal, remitting the matter back to the CIT(E) to provide the assessee with another opportunity to submit the necessary documents and present their case properly.
What were the facts?
The assessee, a trust registered under Section 12A, applied for renewal of registration under Section 12AB. The CIT(E) rejected the application as the assessee failed to submit required documents, including the trust deed and financial details.
What were the issues?
Whether the rejection of registration under Section 12AB was justified due to non-submission of documents, and if the assessee should be granted another opportunity to present their case.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI
Before: SHRI GEORGE GEORGE KAND MS. PADMAVATHY.S
आदेश / O R D E R
PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Exemptions), Chennai (in short "CIT(E)") dated 31.03.2026 rejecting the registration u/s. 12AB of the Income Tax Act, 1961 (in short "the Act").
The assessee is a trust in existence from the year 1997 having registration u/s. 12A of the Act. The assessee filed an application in Form- 10AB for renewal registration before the CIT(E) on 26.08.2025. the CIT(E)
ITA No.1932/Chny/2026 Sri Maharajapuram Santhanam Rasikas Trust :- 2 -:
called for the following documents with regard to the application made for registration: 1. Trust deed/MoA/Instrument creating or establishing the institution. 2. Financial and note on activities. 3. Copy of approval u/s. 12A/12AA obtained in the older regime i.e., prior to 01.04.2021.
Since the assessee did not submit any of the above documents, the CIT(E) rejected the application seeking registration u/s. 12AB of the Act. The assessee is in appeal before the Tribunal against the order of the CIT(E).
We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the old registration u/s. 12A could not be filed before the lower authorities for the reason that the said document was destroyed during Chennai floods and in this regard the Ld. AR drew our attention to the affidavit now given by the managing trustee dated 30.06.2026. The Ld. AR also submitted that the other documents as called for by the CIT(E) were submitted which have not been considered. The Ld. AR also submitted that the assessee is not managed by professionals and therefore the assessee could not represent the case properly before the CIT(E) explaining the reasons for non submission of details. The ld. AR accordingly prayed for one more opportunity. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice and fair play to represent the case properly by producing the required details. Accordingly, we remit the appeal back to the CIT(E) with a direction to call for necessary details and decide the issue in accordance with law. The assessee is directed to submit the necessary details
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as may be called for and cooperate with proceedings. It is ordered accordingly.
In the result, the appeal of the assessee is allowed for statistical purposes.
Order pronounced on 10th day of July, 2026 at Chennai.
Sd/- Sd/- (जॉज� जॉज� के) (पदमावती यस) (Padmavathy.S) (George George K) उपा�� / Vice President लेखा सद�य सद�य /Accountant Member लेखा लेखा लेखा सद�य सद�य चे�नई/Chennai, �दनांक/Dated: 10th July, 2026. EDN, Sr. P.S Digitally signed by आदेश क� �ितिल�प अ�े�षत/Copy to: EJTADA DURGA EJTADA DURGA NARESH 1. अपीलाथ�/Appellant NARESH Date: 2026.07.15 11:31:03 +05'30' 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड फाईल/GF
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