SHRI VENKANTESHWARA SWAMI TEMPLE TRUST,CHANDRAPUR vs. CIT EXEMPTION, PUNE
What did the Tribunal hold?
The Tribunal held that quasi-judicial authorities should decide issues on merits and a mistake in referencing a wrong provision should not lead to dismissal. The principle of substantial compliance should be applied to procedural irregularities.
What were the facts?
The assessee's application for regular approval under Section 12A(1)(ac)(ii) was rejected by the CIT(E) due to an error in mentioning the provision of law under which the application was filed. The assessee argued that this was a technical non-compliance.
What were the issues?
Whether a technical error in mentioning the provision of law in an application for registration under Section 12A(1)(ac)(ii) warrants rejection, or if the principle of substantial compliance should be applied to allow rectification.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, NAGPUR BENCH :: NAGPUR
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 16/09/2025 whereby application for regular approval under Section 12A(1)(ac)(ii) of the Act has been rejected.
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.
We are of the considered view that quasi–judicial authorities are supposed to decide t
The order continues below.
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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
- Lalaram Gupta Charitable Trust, Agra vs ITO, Exemption, AgraITA 660/AGR/2026[2025-26]Status: Disposed15 Oct 2026AY 2025-26
- 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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