CARMEL VIDYA BHAVAN,PUNE vs. CIT(E), PUNE

INCOME TAX APPELLATE TRIBUNAL, PUNE BENCH: A BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER AND SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER

ITA 1937/PUN/2026 Permanent Account Number: AABTL6538M Carmel VidyaBhavan CIT (Exemption), 26/4, Matchwel Road, PMT,Building, Sainikwadi, Pune-411037 Vs. Pune-411014 Maharashtra Maharashtra (प्रत्यर्थीRespondent) (अपीलार्थीAppellant)

निर्धारितीद्वधिध/Assessee represented by: Shri Suhas Kulkarni.AR िधजस्‍वद्वधिध/Revenue represented by: Shri.MithunShete. CIT.DR

सुिवधईकीतधिीख/Date of hearing: 05-08-2026 घोषणधकीतधिीख/Date of pronouncement: 05-08-2026 ORDER PER PAVAN KUMAR GADALE, JUDICIAL MEMBER: The assessee has filed the appeal against the order of CIT(Exemption), Pune passed order u/sec 12AB(1)(b)(ii) of the Income Tax Act. The assessee has raised the grounds of appeal challenging the order of the CIT (Exemption) rejecting the application filed for registration u/sec12AB of the Act. 2. The brief facts of the case are that, the assessee is registered Charitable Trust. The Assessee has applied for registration u/sec 12AB of the Act and was granted provisional registration in Form No. 10AC on 24.09.2021. Subsequently, as per the amended provisions, the assessee for the purpose of permanent registration

ITA 1937/PUN/2026 CarmalVidyaBhavan

has uploaded the application in Form No. 10AB on 30.09.2025 and the office of the CIT (Exemp) has issued notice calling for the details and information and further the assessee was also issued show cause notice to submit the details of activities. Since there was no proper compliance by the assessee and the CIT (Exemp) observed that based on the information submitted, the assessee was registered on 20.05.1977 and has not submitted the old registration certificate u/sec12A of the Act prior to 1.4.2021.Accordingly, CIT(Exemp) has rejected the application vide order dated 22.03.2026. Aggrieved by the CIT (Exemp) order, the assessee has filed the appeal with Hon’ble Tribunal. 3. At the time of hearing, the Ld.AR submitted that the CIT(Exemp) has erred in rejecting the assessee’s application ignoring the submissions made along with application in Form.No.10AB and submissions/ information filed in compliance to notice issued and they were not considered. Further the assessee was not provided the opportunity by the CIT(Exemp) to submit the old registration certificate u/sec12A of the Act prior to 1.4.2021 and rejected the application The Ld.AR submitted that the assessee has a good case on merits and prayed for granting of registration u/sec 12AB of the Act and substantiated the submissions with factual paper book and judicial decisions. Per contra, the Ld.DR supported the order of the CIT(Exemp). 4. We heard the rival submissions and perused the material on record. The assessee has filed the application for the permanent registration u/s 12AB of the Act. Whereas the CIT(Exemp) in the course of hearing, has issued the e-notice and the assessee has filed the details, clarifications and information. The CIT (Exemp) observed that based on the information submitted, the assessee was registered on 20.05.1977 and has not submitted the old registration certificate u/sec12A of the Act prior to 1.4.2021 and rejected the application. The Ld.AR emphasized that the objects of the assesse are charitable in nature and are not disputed. The

ITA 1937/PUN/2026 CarmalVidyaBhavan

Ld. AR submitted that an opportunity may be provided to substantiate the requisite information before the authorities. Hence we considering, the facts, submissions and the principles of natural justice shall provide with one more opportunity of hearing to the assesse to substantiate the case along with evidences and information. Accordingly, we set aside the impugned order and direct the CIT(E) to de- novo consider the application as per the law and we allow the grounds of appeal of the assessee for statistical purposes.

Order pronounced in the open Court on 05th August, 2026.

Sd/- Sd/- MANISH BORAD PAVAN KUMAR GADALE (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) Pune; दिन ांक / Dated: 05th August, 2026. Abhishek Mohan Abhishek Digitally signed by Abhishek Mohan Mohan Date: 2026.08.06 11:26:44 +05'30' आिेशकीप्रतितितिअग्रेतिि / Copy of the Order forwarded to : अिीि र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent. 2. 3. The Pr. CIT concerned. 4. तिभ गीय प्रतितनति, आयकर अिीिीय अतिकरण, “A” बेंच, पुणे/ DR, ITAT, “A” Bench, Pune. ग र्डफ़ इि / Guard File. 5. //True Copy//

आिेश नुस र / BY ORDER,

Assistant Registrar, आयकरअिीिीयअतिकरण, / ITAT, Pune