SHREE DATTA SEVA TRUST ,YAVATMAL vs. CIT EXEMPTION, PUNE

ITA 597/NAG/2025Status: DisposedITAT Nagpur18 June 20266 pages
AI SummaryAllowed

What did the Tribunal hold?

The tribunal held that quasi-judicial authorities should decide issues on merits and a mere reference to a wrong provision should not lead to dismissal. Procedural irregularities should be treated as technical non-compliance, and the assessee should be given an opportunity to rectify mistakes.

What were the facts?

The assessee's application for regular approval under Section 12A(1)(ac)(iii) was rejected by the CIT(E) due to an error in mentioning the specific provision of law. The assessee argued that this was a technical non-compliance.

What were the issues?

Whether a rejection of an application for registration under Section 12A(1)(ac)(iii) solely on the ground of a technical error in mentioning the provision of law is justified, or if the principle of substantial compliance should be applied.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR

For Appellant: Shri Nikhil Mutha, CA
For Respondent: Shri Pankaj Kumar, CIT DR
Hearing: 16.06.2026Pronounced: 18.06.2026

PER ANUBHAV SHARMA, JM:

This appeal filed by the assessee is directed against the order of Ld. Commissioner of Income Tax (Exemption) (for short, “CIT(E)”), dated 16/07/2025 whereby application for regular approval under Section 12A(1)(ac)(iii) of the Act has been rejected.

2.

On hearing both the sides, we find that the impugned order has been passed by Ld. Prescribed Authority observing that there was error in mentioning the provision of law under which the application was filed seeking registration under Section 12A(1)(ac) of the Act.

3.

We are of the considered view that quasi–judicial authorities are supposed to decide the issues on merits and merely reference to a wrong pro

The order continues below.

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