MANCHERJI JOSHI MEMORIAL EDUCATION FUND,MUMBAI vs. CIT (EXEMPTIONS) MUMBAI, MUMBAI

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH: MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No. 3035/Mum/2026 (Assessment Year: 2027-28)

Mancherji Joshi Memorial Commissioner of Income Tax Education Fund (Exemption) 623, Marker Mansion, Lady vs. Room No.601, 6th Floor, Jehangir Road, Parsi Colony, Cumballa Hill Mtnl Te Building, Dadar,, Mumbai, Maharashtra, Pedder Road,, Mumbai, 400014 Maharashtra,

PAN: AAATM5323N (Appellant) (Respondent) For Assessee : Ms. Kaynaz Dadinath Kamdin For Revenue : Shri Sandeep Lakra, CIT DR Date of Hearing : 09.06.2026 Date of Pronouncement : 11.06.2026 O R D E R PER VIKRAM SINGH YADAV, A.M :

This is an appeal filed by the Assessee against the order of the Learned Commissioner of Income Tax (Exemptions), Mumbai [‘Ld.CIT(E)’], dated 28.02.2026, wherein the assessee’s application seeking renewal of registration u/s. 12AB of the Income Tax Act, 1961 (‘the Act’) has been rejected.

Briefly, the facts of the case are that the assessee filed its application 2. in form 10AB u/s. 12A(1)(ac)(ii) on 29.09.2025 seeking renewal of

ITA No. 3035/Mum/2026; A.Y. 2027-28 Mancherji Joshi Memorial Education Fund registration u/s. 12AB of the Act. Subsequently, the notice dated 05.01.2026 was issued calling for the requisite information and documentation in order to verify the contents of the application. However, in absence of necessary compliance by the assessee, the ld. CIT(E) has dismissed the appeal of the assessee on account of non-compliance. Against the said order, the assessee is in appeal before us.

During the course of hearing, the ld. AR submitted that it is a case 3. of a trust, duly registered with the Charity Commissioner, which was established way back in the year 1969 and has got its initial registration u/s. 12A of the Act on 27-12-1975 and thereafter, under the under registration regime, it has been granted provisional registration vide order dated 04.04.2022 and thereafter, it has moved an application in Form 10AB on 29.09.2025 seeking renewal of registration u/s. 12AB of the Act. It was submitted that the notice dated 05.01.2026 was inadvertently delivered to the email ID of the assessee’s previous consultant who was no longer engaged with the assessee trust. As a result, the assessee trust did not receive/become aware of the notice and could not respond to the same within the stipulated timeframe. It was submitted that there was however no willful default or deliberate non-compliance and the lapse was purely procedural and non-intentional. It was submitted that the trust has always complied with all statutory provisions and continues to carry out genuine charitable activities and all documents required to substantiate its activities, accounts and objects are fully available and can be produced before the ld. CIT(E). It was submitted that the assessee be allowed the necessary opportunity and the matter may be remitted to the file of ld. CIT(E) to decide the same afresh.

ITA No. 3035/Mum/2026; A.Y. 2027-28 Mancherji Joshi Memorial Education Fund 4. The ld. DR has been heard, who has relied on the order passed by the ld. CIT(E). At the same time, the ld. DR did not raise any specific objection where the matter is set aside to the file of ld. CIT(E) and decide the same afresh on the merits of the application.

Order pronounced in the open court on 11.06.2026

Sd/- Sd/- SIDDHARTHA NAUTIYAL VIKRAM SINGH YADAV (JUDICIAL MEMBER) (ACCOUNTANT MEMBER) Mumbai, Dated: 11.06.2026 Karishma J. Pawar, SR. PS

ITA No. 3035/Mum/2026; A.Y. 2027-28 Mancherji Joshi Memorial Education Fund

Copy to : 1) The Appellant 2) The Respondent 3) The CIT concerned 4) The D.R, ITAT, Mumbai 5) Guard file

By Order

Dy./Asst. Registrar I.T.A.T, Mumbai