SHREE RATADIA (GANESH) AATH KOTI NANI PAKSH STHANAKWASI JAIN SANGH,GUJARAT vs. ITO (EXEMPTION) WARD 1, RAJKOT, RAJKOT

आयकर अपीलीय अिधकरण, राजकोट �यायपीठ, राजकोट। In The Income Tax Appellate Tribunal, Rajkot Bench, Rajkot Before Dr. Arjun Lal Saini, Accountant Member And Shri Sonjoy Sarma, Judicial Member

आयकर अपील सं./ITA No. 873/RJT/2026 [ �नधा�रण वष�/Assessment Year: - ] Shree Ratadia (Ganesh) Aath Koti Nani ITO (Exemption) Ward 1, Rajkot Paksh Sthanakwasi Jain sangh New Aayakar Bhavan, Vatiaka, Vs. Gaushala Complex, Post Ratadia Rajkot, Gujarat 360001 (Ganesh), Taluk Mundra, Dist Kachchh, Bhuj Gujarat 370001 �थायीलेखासं./जीआइआरसं./PAN/GIR No.: AABTS4605E (अपीलाथ�/Appellant) (��यथ�/Respondent) Appellant by : Shri Ramesh Chheda, Ld. AR Respondent by : Shri Ravinder Sindhu, Ld. CIT. DR Date of Hearing : 30/06/2026 Date of Pronouncement : 07/07/2026

:: ORDER :: Per, Bench: This appeal has been preferred by the assessee against the order dated 08.03.2026 passed by the Ld. Commissioner of Income-tax (Exemption) [CIT(E)], whereby the assessee’s application for registration under Section 12AB read with Section 12A(1)(ac)(vi)(B) of the Income-tax Act, 1961 was rejected. 2. Brief facts of the case are that the assessee is a trust and had filed an application seeking registration under Section 12AB of the Act. During the course of proceedings, the Ld. CIT(E) called upon the assessee to furnish certain details, However, the assessee did not furnish the requisite details despite issuance of notices

ITA No. 873/RJT/2026 Shree Ratadia (Ganesh) Aath Koti Nani Paksh Sthanakwasi Jain sangh and opportunities granted. Accordingly, the application filed by the assessee was rejected on the ground that no documents/details were filed even after issuance of notices. 3. At the outset, it is noticed that the present appeal has been filed with a delay of 4 days. The assessee has filed an application seeking condonation of delay explaining the reasons for the delay. Having considered the averments made in the condonation application and keeping in view the principles of substantial justice, we are satisfied that the assessee was prevented by sufficient cause from filing the appeal within the prescribed period. Accordingly, the delay of 4 days is condoned and the appeal is admitted for adjudication. Aggrieved by the order of the CIT (E) assessee is in appal before this tribunal. 4. At the time of hearing Ld. AR submitted that the non-compliance was not deliberate and that the trust should be afforded one more opportunity to place the necessary documents on record. It was further submitted that in the interest of justice, the matter may be restored to the file of the learned CIT(E) for fresh consideration. 5. On the other hand, the Ld. DR supported the impugned order and submitted that the assessee had failed to comply with the notices issued by the learned CIT(E). 6. We have heard the rival submissions and perused the material available on record. 7. We note that the application for registration has been rejected primarily for non-furnishing of requisite details. Considering that the issue relates to registration of a trust and that the matter should be decided on merits after affording adequate opportunity, we are of the view that one more opportunity deserves to be granted to the assessee. Accordingly, the impugned order is set aside and the matter is restored to the file of the learned CIT(E) for fresh adjudication in accordance with law after

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ITA No. 873/RJT/2026 Shree Ratadia (Ganesh) Aath Koti Nani Paksh Sthanakwasi Jain sangh providing adequate opportunity of hearing to the assessee. The assessee is directed to comply with the notices issued by the learned CIT(E) and furnish all requisite details and documents as may be called for.

Order is Pronounced in the open Court on 07/07/2026.

Sd/-- Sd/-- [ Dr. Arjun Lal Saini ] [ Shri Sonjoy Sarma ] लेखा सद�य/Accountant Member �याियक सद�य/Judicial Member राजकोट/Rajkot िदनांक/ Date: 07/07/2026 Copy of the order forwarded to : 1. The assessee 2. The Respondent 3. CIT 4. The CIT(A) 5. DR, ITAT, Rajkot 6. Guard File By order //True Copy// Sr. Private Secretary ITAT, Rajkot

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