TRINITY FULL GOSPEL MINISTRIES,PUDUCHERRY vs. CIT (EXEMPTION), CHENNAI, CHENNAI

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ITA 2345/CHNY/2026Status: DisposedITAT Chennai29 June 2026AY 2027-283 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal found that the assessee had submitted all required documents and complied with the law. The CIT(E) had ignored the submitted documents while rejecting the application.

What were the facts?

The assessee, a charitable trust, applied for renewal of its registration under Section 12AB. The CIT(E) rejected the application citing non-submission of the Trust Deed and old registration copy, despite the assessee claiming to have submitted them.

What were the issues?

Whether the CIT(E) erred in rejecting the application for registration renewal without considering the documents submitted by the assessee.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 12A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HONOURABLE SHRI ABY T. VARKEY & SHRI GAGAN GOYAL

Hearing: 18.06.2026Pronounced: 29.06.2026

आयकर अपीलीय अधिकरण ‘सी’ न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI माननीय श्री एबी टी. वर्की, न्याययक सदस्य एवं श्री गगन गोयल लेखा सदस्य के समक्ष BEFORE HONOURABLE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 2345/Chny/2026 ननिाारण वर्ा /Assessment Years: 2027-28 Trinity Full Gospel Ministries, v. The Commissioner of Income No.96, Savaripadayachi Street, Nellithope, Tax (Exemption), Puducherry, Chennai. Pondicherry-605 005. [PAN: AABTT0168R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee by : Mr. Meenakshi Sundar, C.A, Ld. AR प्रत्यर्थी की ओर से /Revenue by : Mr. Chilaka Marthi Vijay Raju, Addl. CIT, Ld. DR सुनवाईकीतारीख/Date of Hearing : 18.06.2026 घोषणाकीतारीख /Date of Pronouncement : 29.06.2026 आदेश / O R D E R PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of Ld. Commissioner of Income Tax (Exemption), Chennai (hereinafter referred as the ‘Ld. CIT(E)’) dated 29.03.2026, for the Assessment Year (hereinafter referred as the ‘AY’) 2027-28.

GROUNDS OF APPEAL 1. The order passed by the Learned CIT (Exemption), Chennai is bad in law and against the principles of Natural Justice. 2. The Learned CIT (E) erred in rejecting the application filed in Form 10AB on the ground that the appellant had not furnished the copy of the Trust Deed and copy of the registration granted under the old tax regime without considering the fact that both the documents have been duly submitted by the appellant on 29.01.2026. Page 1 of 3

ITA No.2345/Chny/2026 (2027-28) Trinity Full Gospel Ministries 3. The appellant craves leave to file additional grounds at the time of hearing.

Prayer:

The appellant humbly prays that the Hon'ble Tribunal may direct the CIT (Exemption), Chennai to grant approval for registration u/s. 12AB (1) (b) of the Act for the application filed in Form 10AB, as all the necessary documents have already been submitted by the appellant.

2.

The brief facts of the case are that the assessee is a public charitable trust formed on 18.11.2004 and was originally registered u/s. 12A of the Act w.e.f. 08.03.2005. As per new law also, the assessee was registered u/s. 12A (1) (ac)(i) of the Act vide order dated: 15.03.2022 effective for the period A.Y. 2022-23 To 2026- 27. Then, in anticipation of the provisions of section 12A (1) (ac)(ii) of the Act the assessee again applied for the renewal of its registration vide application dated: 24.09.2025. In response to the application of the assessee dated: 24.09.2025, the office of the Ld. CIT(E), Chennai issued a notice vide dated: 31.12.2025 seeking certain information/documents from the assessee alongwith an undertaking to meet the requirements of section 12A (1) (ac)(ii) of the Act vide page nos. 9 to 12 of the paper book dated: 18.06.2026.

3.

It is observed that the assessee submitted all the relevant documents as desired by the office of the Ld. CIT(E), Chennai and prescribed in section 12A (1) (ac)(ii) of the Act vide e-proceedings response acknowledgement furnished before us vide page nos. 13 and 14 of the paper book dated: 18.06.2026 and copies of the submissions made vide page nos. 15-37 of the paper book dated: 18.06.2026. Then again there was a communication between the assessee and the office of the Ld. CIT(E), Chennai vide 38 to 60 of the paper book dated: 18.06.2026.

4.

Still, the application of the assessee filed in Form No. 10AB was rejected vide order dated: 29.03.2026 assigning the reason that the applicant had not submitted the trust deed and copy of the registration u/s. 12A of the Act obtained prior to 01.04.2021. The assessee being aggrieved with the same preferred the present appeal before us. We have gone through the application in Form No. 10AB filed by the assessee alongwith the order of the Ld. CIT(E), Chennai vide dated: 29.03.2026. We have duly considered the replies of the assessee submitted online in response to

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ITA No.2345/Chny/2026 (2027-28) Trinity Full Gospel Ministries the enquiries made by the office of the Ld. CIT(E), Chennai and the same are find to be in order. Rather, vide dated: 29.01.2026 and again on 21.02.2026 the assessee filed all the relevant documents as prescribed, but the Ld. CIT(E), Chennai ignored the same and rejected the application of the assessee.

5.

We have gone through the submissions of the assessee alongwith evidences produced before us and found that the assessee duly complied with all the requirements of the law and there was no pendency at the end of the assessee in terms of response and submissions of the documents. In the result, ground taken by the assessee is allowed and the Ld. CIT (E), Chennai is directed to correct its record and further directed to grant approval for registration u/s. 12AB of the Act.

6.

In view of the above, the appeal of the assessee is allowed with above observations and directions. Order pronounced on the 29th day of June, 2026, in Chennai.

Sd/- Sd/- (एबी टी. वर्की) (गगन गोयल) (ABY T. VARKEY) (GAGAN GOYAL) न्याययक सदस्य/JUDICIAL MEMBER लेखा सदस्य/ACCOUNTANT MEMBER चेन्नई/Chennai, ददनाांक/Dated: 29th June, 2026. KB आदेश की प्रयतललपप अग्रेपषत/Copy to: 1. अपीलार्थी/Appellant 2. प्रत्यर्थी/Respondent 3. आयकर आयुक्त/CIT, Chennai /Madurai/Coimbatore/Salem 4. पवभागीय प्रयतयनधि/DR Digitally signed 5. गार्ड फाईल/GF K BABU by K BABU Date: 2026.07.01 11:43:43 +05'30'

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