V SUKIRA COMMUNITY HEALTH COUNSELLING TRUST,ERODE vs. CIT EXEMPTIONS, CHENNAI

From a perusal of the impugned orders, we find that the ld. CIT(E) has rejected the applications primarily on the ground of non- compliance with the notices issued and non-furnishing of the documents considered necessary for examination of the applications. No finding has been recorded on the merits of the objects of the trust or the genuineness of its activities after examining the relevant materials. The rejection is thus founded solely on the alleged non-compliance.

In our considered opinion, the issue involved relates to grant of registration u/s. 12AB and approval u/s. 80G, which have significant civil consequences for the assessee. Therefore, before rejecting such applications, the authority is expected to afford an effective and meaningful opportunity to the applicant/assessee to furnish the requisite documents and explain its case. The principles of natural

Considering the facts and circumstances of the case, we are of the view that the ends of justice would be met if the impugned orders are set aside and the matters are restored to the file of the ld. CIT(E) for fresh adjudication. Accordingly, both the impugned orders dated 16.03.2026 passed u/s. 12AB and section 80G are hereby set aside. The ld. CIT(E) shall re-examine the applications afresh in accordance with law after providing adequate and effective opportunity of hearing to the assessee. The assessee shall also extend full cooperation by furnishing all the documents, information and explanations that may be called for by the ld. CIT(E) without seeking unnecessary adjournments.

We clarify that we have not expressed any opinion on the merits of the assessee's entitlement to registration u/s. 12AB or approval u/s. 80G. All issues are left open for consideration by the ld. CIT(E) in accordance with law.

In the result, both the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on the 04th day of August 2026 in Chennai.