S. PUSHPINDER SINGH MEMORIAL TRUST,NEW DELHI vs. WARD EXEMP 2(3) NEW DELHI, NEW DELHI

आयकर अपीलीय अिधकरण, िद�ी पीठ�, नई िद�ी INCOME TAX APPELLATE TRIBUNAL, DELHI BENCHES, ‘A’ NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER ITA 4978 & 4979/DEL/2026 िनधा�रण वष�/Assmt. Year: 2027-28 ONWARDS) S. PUSHPINDER SINGH WARD EXEMP 2(3) NEW MEMORIAL TRUST DELHI M-103 , GREATER KAILASH, NEW DELHI Vs. PART-1 , NEW DELHI 110048, NEW DELHI-110029, DELHI NEW DELHI-110048, DELHI (अपीलाथ� Appellant) (��थ� Respondent) Permanent Account Number of Assessee: AAPTS4012F िनधा�रती �ारा/Assessee represented by: NONE राज� व �ारा/Revenue represented by: Sh Rajore Satish Chandra Ramsevak,CIT DR

सुनवाई की तारीख / Date of conclusion of hearing: 22.06.2026 घोषणा की तारीख / Date of pronouncement: 24.06.2026

ORDER PER AMITABH SHUKLA, AM,

These two appeals by the assessee are directed against the order of the Ld. Commissioner of Income Tax(Exemption), New Delhi [hereinafter referred to as ‘ld. CIT(E)] both dated 03.03.2026 passed under section 12AB(1)(b)(ii) and 80G of the Income Tax Act, 1961, for the Assessment Year 2027-28. The word ‘Act’ herein this order would mean Income Tax Act, 1961.

ITA 4978 & 4979/DEL/2026 S. PUSHPINDER SINGH MEMORIAL TRUST 3. The appeal of the assessee vide ITA No.4978/Del/2026 is regarding the rejection of its request filed under section 80G(5)(ii) of the Act. The appeal of the assessee vide ITA No.4979/Del/2026 is regarding the rejection of its request filed under section 12A(1)(ac)(ii) of the Act. As both the appeals are of the same assessee concerning common issues of rejection of its application under section 12A and 80G, they were heard together and for the purposes of convenience, adjudicated by this common order. 4. We have heard ld. DR in the light of materials available on record. The appeal of the assessee vide ITA No.4979/Del/2026 is regarding the rejection of its request filed under section 12A(1)(ac)(ii) of the Act. As regards, the appeal of the assessee vide ITA No.4978/Del/2026 is regarding the rejection of its request filed under section 80G(5)(ii) of the Act. 5. The ld. DR placed reliance upon the orders of the lower authorities. 6. Upon consideration of orders of Ld. CIT(E) contested by the appellant assessee through impugned appeals, we find that the applications have been rejected without due consideration of facts of records alluding towards a non- application of mind. We have noted that the ld. CIT(E) has dismissed assessee’s application for grant of registration under section 12A and u/s 80G purely on account of non-compliance of the assessee. Reasonable opportunity of being heard is right of every tax payer. Be that as it may be in the interest of justice, we deem it appropriate to set-aside the impugned orders of the ld. CIT(E) and remit the matter of grant of registration u/s 12A as well as u/s 80G back to ld.

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ITA 4978 & 4979/DEL/2026 S. PUSHPINDER SINGH MEMORIAL TRUST

CIT(E) for adjudication de novo in accordance with law. Due opportunity of being heard shall be given to the assessee. The assessee shall comply with all the statutory notices and any non-compliance shall be adversely viewed. Accordingly, the appeals of the assessee vide ITA No.4979/Del/2026 and vide ITA No. 4978/Del/2026 are allowed for statistical purposes. 7. Finally, both the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on 24th June, 2026. Sd/- Sd/- [ANUBHAV SHARMA] [AMITABH SHUKLA] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 24.06.2026 Shekhar Copy forwarded to: 1. Appellant 2. Respondent 3. PCIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi,

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