SAMVEDANA,PUNJAB vs. CIT(E), CHANDIGARH , CHANDIGARH

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ITA 1859/CHANDI/2025Status: DisposedITAT Chandigarh06 July 2026AY 2026-272 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal set aside the impugned orders, restoring the applications back to the CIT(E) for fresh adjudication. The assessee was directed to plead and prove its case. The decision was based on principles of natural justice and the assessee being a charitable trust.

What were the facts?

The assessee's application for registration under Section 12A(1)(ac)(iii) was rejected by the CIT(E) for failing to provide requisite submissions. Consequently, the application for registration under Section 80G(5) was also denied.

What were the issues?

Whether the rejection of registration applications under Section 12A and 80G was justified due to non-submission of documents, and if a remand is appropriate to allow the assessee to present its case.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 80G(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Heard together (2 matters)

ITA No.1859/CHANDI/2025
ITA No.1860/CHANDI/2025

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH PHYSICAL HEARING BEFORE HON’BLE SHRI LALIET KUMAR, JM AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM 1. आयकर अपील सं./ ITA No.1859/CHANDI/2025 & 2. आयकर अपील सं./ ITA No.1860/CHANDI/2025 Samvedna CIT (E) 5th Floor, C.R. Building 1253, Phase-5, SAS Nagar बनाम/ Vs. Sector-60, Mohali - 160059 Himalaya Marg, Sector – 17E Chandigarh - 160017 �ायीलेखासं./जीआइआरसं./PAN/GIR No. ABLAS-3256-R (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Sh. Parikshit Aggarwal (CA) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Geetinder Mann (CIT) – Ld. DR सुनवाईकीतारीख/Date of Hearing : 01-07-2026 घोषणाकीतारीख /Date of Pronouncement 06-07-2026 : आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by rejection of an application as filed by the assessee seeking registration u/s 12A(1)(ac)(iii) and consequential rejection of application seeking registration u/s 80G(5) vide impugned orders dated 12-11-2025 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeals before us. Upon perusal of para 3.2 of rejection order u/s 12A(1)(ac)(iii), it could

be seen that the whole basis of rejection is the fact that the assessee failed to file the requisite submissions / documents as called for by Ld. CIT(E). Consequently, approval u/s 80G was also denied. Aggrieved, the assessee is in further appeals before us. The Ld. AR pleaded that the assessee is in a position to substantiate the genuineness of its activities and accordingly, sought remand back of its applications. The same has been opposed by Ld. CIT-DR. 2. Keeping in mind the principles of natural justice and in view of the fact that the assessee is a charitable trust, we accept the prayer of Ld. AR. Accordingly, the impugned orders are set aside and the issue of registrations stand restored back to Ld. CIT(E) for fresh adjudication with a direction to the assessee to plead and prove its cases forthwith. 3. Both the appeals stand allowed for statistical purposes. Order pronounced on 06th July, 2026 -Sd- -Sd- (LALIET KUMAR) (MANOJ KUMAR AGGARWAL) JUDICIAL MEMBER ACCOUNTANT MEMBER AS Dated: 06-07-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

ASSISTANT REGISTRAR ITAT CHANDIGARH

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