B N JAIN MEMORIAL TRUST,DELHI vs. CIT(EXEMPTION, DELHI
What did the Tribunal hold?
The Tribunal found that the CIT(E)'s rejection of the application for want of documents already on record was arbitrary and unsustainable. The matter was restored to the CIT(E) for a fresh decision after providing a fair opportunity of being heard to the assessee.
What were the facts?
The assessee trust filed an application for registration under section 80G of the Income Tax Act. The CIT(E) rejected the application for want of documents, which the assessee claimed were already on record.
What were the issues?
Whether the CIT(E) erred in rejecting the application for registration under section 80G for want of documents already on record, thereby violating the principles of natural justice.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, DELHI BENCH “F”, NEW DELHI
Before: SHRI S. RIFAUR RAHMAN & SHRI VIMAL KUMAR
IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “F”, NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No. 4143/Del/2026, A.Y. 2026-27 B N Jain Memorial Trust Vs. CIT(Exemption), C-1/52, Janakpuri, Civic Centre, New Delhi New Delhi �थायीलेखासं./जीआइआरसं./PAN/GIR No: AAATB0312L Appellant .. Respondent Appellant by : None Respondent by : Shri Yashvendra Singh, CIT-DR Date of Hearing 23.06.2026 Date of Pronouncement 23.06.2026
O R D E R PER VIMAL KUMAR, JM:
The appeal filed by the assessee is directed against the order dated 12.03.2026 under section 80G of the Income Tax Act, 1961 (hereinafter
P a g e | 2 ITA No. 4143Del/2026 B N Jain Memorial Trust
referred to as “the Act”) of the Commissioner of Income Tax (Exemption), Delhi [hereinafter referred to as “the CIT(E)”] for A.Y. 2026-27.
None appeared for appellant/assessee. In grounds of appeal, it is submitted that Ld. CIT(E) erred in rejecting application for want of documents that were already on record in violation of Principle of natural justice.
Ld. Departmental Representative relied on impugned order.
From examination of record, it is crystal clear that Ld. CIT(E) vide impugned order rejected the application for registration u/s 80G of the Act for want of documents already on record is arbitrary and not sustainable in law. In view of above material facts and in the interest of substantial justice, impugned order is set aside and the matter is restored to the file of Ld. CIT(E) for fresh decision in accordance with law after affording fair opportunity of being heard to the assessee. We also direct assessee to make proper submissions and appear before the Ld. CIT(E) on the date of hearing and cooperate with the tax authorities.
P a g e | 3 ITA No. 4143Del/2026 B N Jain Memorial Trust
In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court on 23.06.2026
Sd/- Sd/- (S. RIFAUR RAHMAN) (VIMAL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 30.06.2026 Binita, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT ASSISTANT REGISTRAR ITAT, NEW DELHI
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