SHIRDI SAI-SAKTHI FOUNDATION TRUST,KANCHIPURAM vs. CIT (EXEMPTION), CHENNAI

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ITA 2771/CHNY/2026Status: DisposedITAT Chennai04 August 2026AY 2026-20273 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, considering the assessee's plea of lack of technical expertise and inadequate professional support, granted one more opportunity for proper representation. The appeals were remitted back to the CIT(E) for fresh adjudication.

What were the facts?

The assessee, a charitable trust, applied for registration under sections 12A and 80G of the Income Tax Act. The CIT(E) rejected the application for non-submission of mandatory documents and details.

What were the issues?

Whether the CIT(E) was justified in rejecting the application for registration due to non-submission of documents, and if the assessee should be granted another opportunity.

Which sections of the Income-tax Act were involved?

Section 12A,Section 80G,Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI

Before: SHRI GEORGE GEORGE K & MS. PADMAVATHY.S

For Respondent: Mr. Shiva Srinivas, CIT

आदेश / O R D E R

PER PADMAVATHY.S, A.M: These appeals by the assessee are against the order of the Commissioner of Income Tax (Exemptions), Chennai (in short "CIT(E)") dated 19.03.2026 rejecting the application made for registration u/s. 12A & 80G of the Income Tax Act, 1961 (in short "the Act").

ITA Nos.2770 & 2771/Chny/2026 Shiridi Sai Sakthi Foundation Trust :- 2 -: 2. The assessee is a charitable trust. The assessee filed an application in Form-10AB on 30.09.2025 before the CIT(E) seeking registration u/s. 12AB of the Act. The CIT(E) called on the assessee to furnish the following mandatory documents: 1. Trust deed creating/establishing the institution 2. Note on the activates of the trust 3. Copy of approval/registration u/s. 12A/12AA obtained prior to 01.04.2021 4. Financial statements for FY 2022-23 to 2024-25.

3.

The assessee did not respond to the notice called for the above details and therefore the CIT(E) rejected the application made by the assessee. The CIT(E) also rejected the registration u/s. 80G of the Act for the same reason that the assessee did not submit any details. The assessee is in appeal before the Tribunal against the order of the CIT(E).

4.

We have heard the parties, and perused the material available on record. The Ld. Authorized Representative (AR) of the assessee submitted that the assessee is managed by persons who are not well versed in computers and therefore not aware of the income tax proceedings. The Ld. AR further submitted that the assessee therefore completely relied on its counsel for handling the tax matters and the counsel of the assessee did not provide proper professional support. The Ld. AR also submitted that therefore the assessee could not represent the case properly before the CIT(E). The Ld. AR accordingly prayed for one more opportunity. Considering the facts and circumstances peculiar to assessee's case, we are inclined to give one more opportunity to the assessee in the interest of natural justice and fair play to represent the case properly by producing the required details. Accordingly, we remit the appeal back to the CIT(E) with a direction to call for necessary details and decide the issue of registration u/s. 12A and 80G in accordance

ITA Nos.2770 & 2771/Chny/2026 Shiridi Sai Sakthi Foundation Trust :- 3 -: with law. The assessee is directed to submit the necessary details as may be called for and cooperate with proceedings. It is ordered accordingly.

5.

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

Order pronounced on 04th day of August, 2026 at Chennai.

Sd/ Sd/ (जॉज� जॉज� के) (पदमावती यस) (Padmavathy.S) (George George K) उपा�� / Vice President लेखा लेखा सद�य लेखा लेखा सद�य सद�य /Accountant Member सद�य चे�नई/Chennai, �दनांक/Dated: 04th August, 2026. EDN, Sr. P.S EJTADA Digitally signed by आदेश क� �ितिल�प अ�े�षत/Copy to: EJTADA DURGA NARESH DURGA Date: 2026.08.07 1. अपीलाथ�/Appellant NARESH 17:57:10 +05'30' 2. ��थ�/Respondent 3. आयकर आयु�/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय �ितिनिध/DR 5. गाड� फाईल/GF

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