M S ROOHANI SATSANG SOCIETY,HARYANA vs. EXEMPTIONS WARD, ROHTAK, HARYANA
What did the Tribunal hold?
The Tribunal found that the CIT(E) rejected the application due to non-compliance by the assessee. However, in the interest of justice, the Tribunal decided to restore the issue to the CIT(E) to grant one final opportunity to the assessee to substantiate its claim.
What were the facts?
The assessee's application for registration under Section 12AB of the Income Tax Act was rejected by the CIT(E) due to a failure to provide requisite documents and evidence, despite seeking adjournments. The assessee contended that the rejection was mechanical and passed without a proper inquiry or opportunity to be heard.
What were the issues?
Whether the CIT(E) erred in rejecting the registration application without a proper inquiry and opportunity to be heard, and if a final opportunity should be granted to the assessee.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH “A”, DELHI
Before: SH. SUDHIR KUMAR, & SH. MANISH AGARWAL
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “A”, DELHI
BEFORE SH. SUDHIR KUMAR JUDICIAL MEMBER, AND SH. MANISH AGARWAL, ACCOUNTANT MEMBER
ITA No.714/DEL/2026 Assessment Year: ---- M.S. Roohani Satsang Vs. CIT (Exemptions) Society, Chandigarh Khuspur Dham Rania Road Village Goriwala Sirsa - 125055 Haryana PAN No. AACTM8981G (APPELLANT) (RESPONDENT)
Appellant by Sh. Shivam Singh, Adv. Respondent by Sh. Jitender Singh, CIT DR
Date of hearing: 30/04/2026 Date of Pronouncement: 30/04/2026 ORDER PER SUDHIR KUMAR, JUDICIAL MEMBER:
This appeal by the assessee is directed against the orders
of the Commissioner of Income Tax (Exemption), Chandigarh
[hereinafter referred to as “CIT(E)”] vide order dated 10.11.2025.
The assessee has raised the following grounds in appeal:-
That the Worthy CIT(E), Chandigarh has erred, both in law and on facts in rejecting the appellant’s application for registration u/s 12A(1)(ac) (ii) r.w.s. 12AB vide order dt. 10-11-2025, is contrary to law, facts and procedure and therefore liable to be quashed. 2. That on facts and legal position of the case, the Worthy CIT(E) has erred in passing a mechanical, non -speaking and cryptic order without conducting the mandatory inquiry into the appellant’s objects, accounts, activities and evidences on record. 3. That on facts, circumstances of the case the order passed by worthy CIT(E) deserves to be quashed since the same has been passed without affording reasonable opportunity of being heard to the appellant. 4. That the appellant craves leave for any addition deletion or amendment in the grounds of appeal on or before the disposal of the same. 3. The Ld. CIT(E) rejected the application by order dated 10-
11-2025 observing as under:
In view of the above discussions, the present application of the applicant filed in Form 10AB u/s 12A(1)(ac)(ii) of the Act is disposed of as being deficient in factual evidences in the absence of the requisite submissions of the applicant at the scheduled hearings. Accordingly, the application filed by the applicant for registration u/s 12AB of the Act is hereby rejected and this rejection will also
supersede any registration granted u/s 12AB of the Act by any authority at any earlier time. 4. The Ld. DR has submitted that the Ld. AR has failed to
provide the relevant documents before the Ld. CIT (E), the
application was rightly.
We have heard the rival contentions and perused the
material available on record. The assessee has filed the part
details before the Ld. CIT(E) regarding the trust and also sought
adjournment but assessee has failed to file the relevant
documents/ evidences. The Ld. CIT(E) rejected the registration
application u/s 12AB of the Act. Since in the instant case the
Ld. CIT(E) has dismissed the appeal in non-compliance
therefore, considering the totality of the facts and
circumstances of the case and in the interest of justice, we
deem it proper to restore the issue to the file of the Ld. CIT(E)
with a direction to grant one final opportunity to the assessee to
substantiate , its claim and decide the issue as per fact and law.
The assessee is also directed to appear before the Ld. CIT(E) and
co-operate in the proceedings. The grounds raised by the
assessee are accordingly allowed for statistical purposes.
In the result, the appeal of the assessee is allowed for statistical purpose. Order pronounced in the open court on 30.04.2026.
Sd/- Sd/- (MANISH AGARWAL) (SUDHIR KUMAR) ACCOUNTANT MEMBER (JUDICIAL MEMBER) SR BHATNAGGAR Date: 07.05.2026 Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) ` 5. DR: ITAT ASSISTANT REGISTRAR ITAT DELHI
More judgments on Section 12A(1)(ac)(ii)
- Sanskardham Nandan, Mehsana vs CIT(Exemption), AhmedabadITA 2980/AHD/2026[2025-26]Status: Disposed16 Oct 2026AY 2025-26
- Ss Early Learning Society, Hyderabad vs CIT (Exemption), HyderabadITA 1208/HYD/2025[2026-27]Status: Disposed16 Oct 2026AY 2026-27
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- Lalaram Charitable Trust, Agra vs ITO, Exemption, AgraITA 659/AGR/2026[2025-26]Status: Disposed15 Oct 2026AY 2025-26
- Shri Brajshiromani Laxmandas Sewa Trust… vs Income-Tax Officer, Ward 1(3)(1), Mathura…ITA 592/AGR/2026[2026-2027]Status: Disposed14 Oct 2026AY 2026-2027
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