THE CATHEDRAL CHURCH OF THE REDEMPTION,DELHI vs. CIT (EXEMPTIONS) , DELHI

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ITA 3634/DEL/2026Status: DisposedITAT Delhi22 June 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the principles of natural justice were violated as the CIT(E) passed an ex parte order. The matter was set aside and restored to the CIT(E) for a fresh decision after affording an opportunity of hearing to the assessee.

What were the facts?

The assessee filed appeals against the order of the CIT(Exemptions) rejecting registration under section 12A and 80G of the Income Tax Act. The CIT(E) passed an ex parte order without considering the facts and circumstances.

What were the issues?

Whether the CIT(E) followed the principles of natural justice while rejecting the registration under section 12A. Whether the ex parte order passed by the CIT(E) was valid.

Which sections of the Income-tax Act were involved?

Section 12A,Section 80G

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

For Appellant: Shri George Koshi, CA
For Respondent: Shri Yashvendra Singh, CIT-DR
Hearing: 22.06.2026Pronounced: 22.06.2026

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. 3633/Del/2026 ITA No. 3634/Del/2026 The Cathedral Church of Vs. CIT (Exemptions) the Redemption Delhi Church Road, Delhi �थायीलेखासं./जीआइआरसं./PAN/GIR No: AAATT0498D Appellant .. Respondent Appellant by : Shri George Koshi, CA Respondent by : Shri Yashvendra Singh, CIT-DR Date of Hearing 22.06.2026 Date of Pronouncement 22.06.2026

O R D E R PER VIMAL KUMAR, JM:

The appeals filed by the assessee against the order dated 11.03.2026, under section 12A and 80G of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) of the Commissioner of Income Tax (Exemption), Delhi [hereinafter referred to as “the CIT(E)”].

P a g e | 2 ITA No3633 nd 3634/Del/2026 The Cathedral Church of the Redemption

2.

Heard both the parties and perused the material on record. We observed that the Ld. CIT(E) rejected the registration under section 12A of the Act, without considering facts and circumstances of the case. Ld. CIT(E) has passed ex parte order in violation of principle of natural justice.

3.

From examination of record, it is crystal clear that principles of natural justice have not been followed by the appellant authority. Therefore, we direct Ld. CIT(E) to give an opportunity of being heard to the assessee and decide the issue on merit as per law. It is considered expedient to set aside the orders of the Ld. CIT(E) and restored the matter to the files of the ld. CIT(E) for a fresh decision in accordance with law, after affording fair opportunity of hearing 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.

4.

Similarly, the assessee is in appeal before us by filing separate appeal vide ITA No. 3634/Del/2026. We remit this issue also back to the file of Ld. CIT(E) in the interest of justice. Both the issues under consideration may be decided as per law.

P a g e | 3 ITA No3633 nd 3634/Del/2026 The Cathedral Church of the Redemption

5.

In the result, the appeals filed by the assessee are allowed for statistical purposes.

Order pronounced in the open court on 22.06.2026 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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