ROTARY DISTRICT 3234 CHARITABLE TRUST,CHENNAI vs. DCIT, EXEMPTIONS, , CHENNAI

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ITA 1533/CHNY/2026Status: DisposedITAT Chennai09 July 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the assessee claimed the notices went to their spam folder due to system glitches, and thus did not receive a proper opportunity. Therefore, the Tribunal set aside the CIT(E)'s order and restored the applications for fresh consideration.

What were the facts?

The assessee trust applied for registration under Section 12AB and approval under Section 80G of the Income Tax Act. The CIT(E) rejected the applications alleging no response from the assessee to notices sent.

What were the issues?

Whether the rejection of applications for registration and approval without proper opportunity to the assessee is justified.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI S.R.RAGHUNATHA

Hearing: 12.05.2026Pronounced: 09.07.2026

आदेश / O R D E R PER ABY T. VARKEY, JM: The ITA No.1533/Chny/2026 which is an appeal preferred by the assessee trust against the rejection of its application for registration u/s 12AB of the Income Tax Act 1961 (hereinafter referred as the ‘Act) and the ITA No.1532/Chny/2026 is against the rejection, by the Ld.CIT(E)

ITA Nos.1532 & 1533/Chny/2026 Rotary District 3234 Charitable Trust :: 2 :: (hereinafter referred as the ‘Ld.CIT(E)’), of its application seeking approval u/s. 80G of the Act.

2.

At the outset, the Ld.AR of the assessee drawing our attention to the impugned orders submitted that the Ld.CIT(E) has rejected the applications filed by the assessee alleging no response from the assessee. According to the Ld.AR, the Ld.CIT(E) has alleged to have issued two notices but may be due to the glitches in the internet, the notices might have gone to the Spam account and therefore, the assessee could not reply. Therefore, he pleaded for one more opportunity to the assessee before the Ld.CIT(E).

3.

Per contra, the Ld.DR submitted that the assessee should not be given one more opportunity.

4.

Having heard both the parties and after perusal of the records, it is noted that the assessee has applied for regular registration u/s 12AB and approval u/s 80G of the Act. The Ld.CIT(E) is noted to have issued notice on 19.08.2025 and on 26.11.2025 which did not elicit any response from the assessee which led to the rejection of the application filed by the assessee. The assessee claims to be a charitable organization and has sought regular registration under 12AB and has sought approval under 80G and filed the application before the Ld.CIT(E). The Ld.CIT(E ) finding no response to his notices has rejected the application. In this regard, it

ITA Nos.1532 & 1533/Chny/2026 Rotary District 3234 Charitable Trust :: 3 :: was brought to our notice that the assessee did not receive the notices in its email which got delivered in the Spam account may be due to the glitches in the system. Be that as it may, since the assessee did not get proper opportunity before the Ld.CIT(E), we are of the view that the assessee needs to be given one more opportunity before the Ld.CIT(E) and hence, we set aside the impugned order of the Ld.CIT(E) and restore the application back to his file with a direction to consider the assessee’s application in accordance with law after hearing the assessee. The assessee is directed to file all relevant documents necessary for supporting its case for grant of registration u/s 12AB / 80G of the Act.

5.

In the result, appeals of the assessee are allowed for statistical purposes.

Order pronounced on the 09th day of July 2026, in Chennai. Sd/- Sd/- (एबी टी. वक�) (एस. आर. रघुनाथा) (ABY T. VARKEY) (S.R.RAGHUNATHA) �या�यक सद�य/JUDICIAL MEMBER लेखा सद�य/ACCOUNTANT MEMBER चे�ई/Chennai, िदनांक/Dated: 09th July, 2026. KB आदेश की �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

YASHVI Digitally signed by YASHVIR SINGH R SINGH Date: 2026.07.20 14:37:25 +05'30'

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