M S ROOHANI SATSANG SOCIETY,HARYANA vs. EXEMPTIONS WARD, ROHTAK, HARYANA

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ITA 714/DEL/2026Status: DisposedITAT Delhi07 May 2026AY 2027-284 pages
AI SummaryPartly Allowed

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?

Section 12A(1)(ac)(ii),Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH “A”, DELHI

Before: SH. SUDHIR KUMAR, & SH. MANISH AGARWAL

Hearing: 30/04/2026Pronounced: 30/04/2026

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.

2.

The assessee has raised the following grounds in appeal:-

1.

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:

5.

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.

5.

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.

6.

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

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