What did the Tribunal hold?

The Tribunal condoned the delay due to bona fide circumstances and set aside the CIT's order. The matter was restored to the CIT for a fresh examination of the application after granting a hearing and receiving all requisite documents from the assessee.

The assessee trust's application for registration/approval under the Income Tax Act was rejected by the CIT(Exemptions) for failure to furnish required documents. The appeals were filed with a delay of 65 days.

What were the issues?

Whether the delay in filing appeals should be condoned and if the assessee should be granted another opportunity to furnish documents for registration.

Inspire Safety Foundation vs CIT | ITAT Mumbai 2026

Income Tax Appellate Tribunal, ‘E’ BENCH

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

For Appellant: Shri Devendra Jain

For Respondent: Smt. Amrita Singh, CIT DR

Hearing: 29/06/2026Pronounced: 29/06/2026

आदेश / O R D E R PER BENCH: These appeals have been preferred by the above-named assessee trust against the order dated 12.11.2025 passed by the learned CIT (Exemption), whereby the application filed by the assessee seeking registration/approval under the provisions of the Act has been rejected.

2 ITA No.4549/Mum/2026 & 4550/Mum/2026 Inspire Safety Foundation 2. At the outset, it is noticed that there is a delay of 65 days in filing the present appeals. In support of the application seeking condonation of delay, the assessee has filed a duly sworn affidavit explaining the circumstances leading to the delay. It has been stated that the notices issued during the course of proceedings escaped the attention of the trustee and the in-house administrative assistant as the communications were sent to an inoperative e-mail address, while the trustee was also away from station during the relevant period on account of personal commitments. It has further been explained that the rejection order came to the knowledge of the assessee only when a prospective donor sought the registration particulars of the trust, whereupon immediate steps were taken by consulting professionals and thereafter the present appeals were filed. Having considered the explanation furnished in the affidavit, we are satisfied that the delay was occasioned due to bona fide circumstances and was neither deliberate nor attributable to any lack of diligence. We, therefore, condone the delay of 65 days and proceed to decide the appeals on merits.

On merits, we have heard the rival submissions and perused the material available on record. It is seen that the learned CIT (Exemption) rejected the assessee’s application primarily on the ground that despite issuance of three notices, the assessee failed to furnish the requisite documents and details called for during the course of proceedings. Before us, the learned counsel submitted that the notices issued electronically had inadvertently escaped attention for the reasons explained in the affidavit and,

3 ITA No.4549/Mum/2026 & 4550/Mum/2026 Inspire Safety Foundation therefore, the requisite details could not be furnished before the learned CIT (Exemption). It was further submitted that the assessee is ready and willing to furnish all the documents and fully comply with the requirements if one more opportunity is granted.

Considering the totality of 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 (Exemption) with a direction to examine the assessee’s application afresh in accordance with law after affording a reasonable opportunity of hearing. The assessee is also directed to furnish all the requisite documents, evidences and explanations as may be called for by the learned CIT (Exemption) and extend full cooperation for expeditious disposal of the proceedings.

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

Order pronounced on 29th June, 2026.

Sd/- Sd/- (GIRISH AGRAWAL) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 29/06/2026 KARUNA, sr.ps

4 ITA No.4549/Mum/2026 & 4550/Mum/2026 Inspire Safety Foundation 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

INSPIRE SAFETY FOUNDATION,MUMBAI vs. CIT(EXEMPTIONS), MUMBAI, MUMBAI

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