SHREE LAXMINARAYAN AGARWAL CHARITABLE TRUST,MUMBAI vs. CIT(EXEMPTIONS), MUMBAI, MUMBAI

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ITA 4137/MUM/2026Status: DisposedITAT Mumbai25 June 2026AY 2027-284 pages

In favour of the Revenue: the assessee's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the controversy arising from the rejection order no longer survives as the subsequent grant of registration and approval renders the appeals infructuous. Any grievance regarding conditions in the fresh order can be challenged independently.

What were the facts?

The assessee trust's applications for registration under section 12AB and approval under section 80G were rejected by the CIT(Exemptions). Subsequently, the CIT(Exemptions) passed a fresh order granting both registration and approval.

What were the issues?

Whether appeals against rejection orders for registration and approval are maintainable when fresh orders granting them are subsequently passed. Whether the Tribunal can adjudicate on conditions imposed in a fresh order not under appeal.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘E’ BENCH

Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWAL

For Appellant: Ms. Ranjana Soni
For Respondent: Smt. Amrita Singh, CIT DR
Hearing: 25/06/2026Pronounced: 25/06/2026

आदेश / O R D E R PER BENCH: The aforesaid appeals have been preferred by the assessee trust against the impugned order passed by the learned CIT (Exemption), whereby the applications filed by the assessee seeking registration under section 12AB of the Act and approval under section 80G came to be rejected.

2 ITA No.4137 & 4138/Mum/2026 Shree Laxminarayan Agarwal Charitable Trust 2. At the time of hearing, the learned Counsel for the assessee fairly submitted that subsequent to the passing of the impugned order, the learned CIT (Exemption) has passed a fresh order granting registration under section 12AB as well as approval under section 80G to the assessee trust. It was, however, pointed out that while granting such registration and approval, certain conditions and observations have also been incorporated in the said order, against which the assessee may have an independent grievance.

3.

Having carefully considered the aforesaid submission, we are of the considered opinion that the controversy arising from the impugned order no longer survives for our adjudication. Once the competent authority has subsequently granted the very registration and approval, the rejection order impugned before us ceases to have any operative consequence, and the relief originally sought in these appeals already stands substantially redressed. Thus, no effective or meaningful adjudication can now be undertaken on the validity of the earlier rejection order, as the cause of action giving rise to these appeals has itself become extinct.

4.

However, insofar as the observations, stipulations or conditions incorporated in the subsequent order granting registration under section 12AB and approval under section 80G are concerned, the same do not form the subject matter

3 ITA No.4137 & 4138/Mum/2026 Shree Laxminarayan Agarwal Charitable Trust of the present appeals. If the assessee is aggrieved by any such condition or observation contained therein, it shall be open to it to challenge the said order independently in accordance with law. Needless to clarify, we have expressed no opinion whatsoever on the merits of such conditions or observations.

5.

Accordingly, the present appeals, having lost their substratum on account of the subsequent grant of registration under section 12AB and approval under section 80G, are dismissed as having become infructuous.

6.

In the result, both the appeals of the assessee are dismissed as infructuous.

Order pronounced on 25th June, 2026.

Sd/- Sd/- (GIRISH AGRAWAL) (AMIT SHUKLA) ACCOUNTANT MEMBER JUDICIAL MEMBER Mumbai; Dated 25/06/2026 KARUNA, sr.ps

4 ITA No.4137 & 4138/Mum/2026 Shree Laxminarayan Agarwal Charitable Trust Copy of the Order forwarded to : 1. The Appellant 2. The Respondent. 3. CIT 4. DR, ITAT, Mumbai 5. Guard file. //True Copy// BY ORDER,

(Asstt. Registrar) ITAT, Mumbai

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