KARNATAKA SANGHA,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI, MUMBAI

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ITA 2768/MUM/2026Status: DisposedITAT Mumbai30 June 2026AY 2027-284 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the applications were not rejected on merits regarding the trust's objects or activities, but due to non-compliance with documentation requirements. In the interest of substantial justice, the matter was restored to the CIT(Exemptions) for a fresh decision after providing the assessee with another opportunity to submit documents.

What were the facts?

The assessee trust applied for renewal of registration under section 12AB and approval under section 80G. The CIT(Exemptions) rejected both applications solely on the ground that the assessee failed to furnish requisite details and supporting documents.

What were the issues?

Whether the rejection of applications for registration and approval solely on the ground of non-furnishing of documents, without examining the merits, is justified. Whether the assessee should be granted another opportunity to submit the required documents.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘E’ BENCH

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

For Appellant: Shri Bhupendra Shah
For Respondent: Smt. Amrita Singh, CIT DR
Hearing: 25/06/2026Pronounced: 30/06/2026

आदेश / O R D E R PER AMIT SHUKLA (J.M): These appeals have been filed by the assessee trust against the separate but identical orders dated 28.02.2026 passed by the learned CIT (Exemption), whereby the assessee’s applications seeking renewal of registration under section 12AB of the Act and approval under section 80G of the Act have been rejected.

2 ITA No.2767 & 2768/Mum/2026 Karnataka Sangha 2. The sole basis on which the learned CIT (Exemption) has rejected both the applications is that the assessee had allegedly failed to furnish the requisite details and supporting documents called for during the course of the proceedings. It has been observed in the impugned orders that a notice dated 11.01.2026 was issued requiring the assessee to furnish the complete set of documents and information as prescribed under Rule 17A(2) of the Income Tax Rules. According to the learned CIT (Exemption), since the said notice was not complied with and the applications remained incomplete, both the applications came to be rejected.

3.

Before us, the learned counsel submitted that the rejection has been made without proper appreciation of the facts and that the assessee is willing to furnish all the requisite documents and details as may be required by the learned CIT (Exemption). It was, therefore, submitted that in the interest of substantial justice, one effective opportunity may be granted to the assessee to place all the relevant material on record so that the applications may be examined on merits in accordance with law. The learned Departmental Representative fairly left the issue to the discretion of the Bench.

4.

We have carefully considered the rival submissions and perused the material placed on record. The impugned orders reveal that the applications have not been rejected on account of any adverse finding regarding the objects or activities of the assessee trust, but solely on the ground that the requisite documents and information were not furnished to the satisfaction of the learned CIT

3 ITA No.2767 & 2768/Mum/2026 Karnataka Sangha (Exemption). Since the issue has not been examined on merits and considering that grant or refusal of registration under section 12AB and approval under section 80G has far reaching consequences, in the interest of substantial justice, we deem it appropriate to restore the entire matter to the file of the learned CIT (Exemption). The learned CIT (Exemption) shall afford one more effective and reasonable opportunity of hearing to the assessee, consider all the documents and evidences that may be furnished, and thereafter decide the applications afresh in accordance with law by passing a speaking and reasoned order. The assessee is also directed to extend full cooperation and furnish all the requisite details and documents as may be called for without seeking unnecessary adjournments.

5.

In the result, both the appeals of the assessee are allowed for statistical purposes.

Order pronounced on 30th June, 2026.

Sd/- Sd/- (GIRISH AGRAWAL) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 30/06/2026 KARUNA, sr.ps

4 ITA No.2767 & 2768/Mum/2026 Karnataka Sangha Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy//

BY ORDER,

(Asstt. Registrar) ITAT, Mumbai

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