SATGURU HINDU SEVA TRUST,TIRUVANNAMALAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHENNAI

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ITA 1921/CHNY/2026Status: DisposedITAT Chennai30 June 2026AY 2026-273 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal and, considering the interest of justice, remanded the matter back to the CIT(Exemption) for fresh consideration. The assessee was granted an opportunity to present its case with supporting evidence.

What were the facts?

The assessee trust filed an application for registration under Section 12AB of the Income Tax Act. The CIT(Exemption) rejected the application for non-compliance with notices, despite the assessee claiming bona fide reasons for delay in filing the appeal.

What were the issues?

Whether the CIT(Exemption) was justified in rejecting the registration application without providing adequate opportunity, and whether the assessee's delay in responding to notices was excusable.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac),Section 12AB

AI-generated summary — verify with the full judgment below

Before: Shri Inturi Rama Rao & Shri S.S. Viswanethra Ravi

Hearing: 15.06.2026Pronounced: 30.06.2026

आयकर अपीलीय अिधकरण, ’ए’ �ायपीठ, चे�ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI �ी इंटूरी रामाराव, लेखा सद� एवं �ी एस.एस. िव�ने� रिव, �ाियक सद� के सम� । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.1921/Chny/2026 िनधा�रण वष�/Assessment Year: 2026-27 Satguru Hindu Seva Trust, Vs. The CIT (Exemption), 18 Pey Gopuram 6th Street, Chennai, 600034. Tiruvannamalai, Tamil Nadu, 606601. [PAN: ABETS2374N]

(अपीलाथ�/Appellant) (��थ�/Respondent) अपीलाथ� की ओर से / Appellant by : Mr. Saravanan, Advocate ��थ� की ओर से/Respondent by : Ms. R. Anita, CIT सुनवाई की तारीख/ Date of hearing : 15.06.2026 घोषणा की तारीख /Date of Pronouncement 30.06.2026 : आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 08.12.2025 passed by the ld. Commissioner of Income Tax (Exemption), Chennai.

2.

We find that this appeal was filed with a delay of 33 days. The assessee filed an affidavit accompanied by a petition explaining the reasons. On perusal of the same and upon hearing both the parties, we find that the reasons explained by the assessee are bona fide, which really prevented the assessee from filing the appeal in time. Thus, the delay of 33 days is condoned.

2 I.T.A. No.1921/Chny/26

3.

At the outset, it is noted that the assessee filed an application in Form 10AB under Section 12A(1)(ac) of the Income Tax Act, 1961 (for short, the Act) seeking registration under Section 12AB of the Act, in response to which the ld. CIT(E) issued a notice dated 19.08.2025 through the e-filing ITBA portal, for which, according to the ld. CIT(E), there was no response from the assessee. Further, another show-cause notice dated 26.11.2025 was issued informing the assessee to submit the required details by 03.12.2025 with a rider that, failing which, the application would be disposed of based on the material available on record. Further, according to the ld. CIT(E), the assessee failed to comply with the notice and, in spite of reasonable opportunity, having no option, rejected the application seeking registration under Section 12AB of the Act as non-maintainable, which is evident from para No. 4 of the impugned order.

4.

Ld. AR Mr. Saravanan, Advocate, prayed that the impugned order causes grave prejudice and irreparable hardship to the assessee, as the denial of registration severely hampers its ability to raise funds and carry out its charitable activities for the benefit of the public at large. Ld. AR pleaded for one more opportunity for the assessee, and the assessee is ready to comply with the notices with all relevant documentary evidence.

5.

Ld. DR Ms. R. Anita, CIT, reported no objection.

6.

Having heard both the parties, we note that admittedly there was no assistance before the ld. CIT(E) by the assessee with reference to the relevant documents, details, and clarifications as sought through notices on the ITBA portal, which is evident from para Nos. 2 and 3 of the impugned order. Therefore, considering the submissions of the ld. AR

3 I.T.A. No.1921/Chny/26

and DR and the facts and circumstances of the case, and in the interest of justice, we deem it proper to remand the matter to the file of the ld. CIT(E) for his fresh consideration. The assessee shall represent his case before the ld. CIT(E) without fail and is at liberty to file evidence, if any, in support of his claim. Thus, the order of the ld. CIT(E) is set aside and the grounds raised by the assessee are allowed for statistical purposes.

7.

In the result, the appeal of the assessee is allowed for statistical purpose. Order pronounced on 30th June, 2026 at Chennai.

Sd/- Sd/- (INTURI RAMA RAO) (S.S. VISWANETHRA RAVI) ACCOUNTANT MEMBER JUDICIAL MEMBER Chennai, Dated, 30.06.2026 MM/- आदेश की �ितिलिप अ�ेिषत/Copy to: 1. अपीलाथ�/Appellant, 2.��थ�/ Respondent, 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR & 5. गाड� फाईल/GF.

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