LIFE GIVING WORD,DELHI vs. CIT EXEMPTION, DELHI

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ITA 614/DEL/2026Status: HeardITAT Delhi27 April 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) should have provided the assessee an opportunity to produce documents and be heard before rejecting the applications. The impugned orders were set aside.

What were the facts?

The assessee's applications for registration under Section 12A(1)(ac)(ii) and 80G of the Income Tax Act were rejected by the CIT(E). The assessee argued that the rejection orders were ex-parte and lacked proper verification of documents or opportunity for submission.

What were the issues?

Whether the CIT(E) erred in rejecting the applications for registration without providing an opportunity to the assessee to produce evidence and make submissions.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 80G

AI-generated summary — verify with the full judgment below

Before: SHRI YOGESH KUMAR U.S & SHRI SANJAY AWASTHI

Hearing: 20.04.2026Pronounced: 27.04.2026

1 ITA Nos. 615 & 614/Del/2026 Life Giving Word

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI [ DELHI BENCH: “A” NEW DELHI] BEFORE SHRI YOGESH KUMAR U.S, JUDICIAL MEMBER AND SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER ITANo. 615/DEL/2026 ITA No.614/DEL/2026 Life Giving Word Vs Commissioner of Income Tax Flat No.323, Plot No. 14, Surya (Exemption) Apartments, Sector 6, Dwarka, New Delhi New Delhi (RESPONDENT) PAN: AAATL5263E (APPLICANT) Appellant by Sh. George Koshi, Ca Respondent by Sh. Jitender Singh, CIT DR Date of Hearing 20.04.2026 Date of Pronouncement 27.04.2026

ORDER PER YOGESH KUMAR, U.S. JM: These two appeals are filed by the Assessee against the orders of

the Commissioner of Income Tax (Exemption)-, Delhi (‘Ld. CIT(E)’ for

short) dated 22/12/2025 wherein the applications filed by the

Assessee for grant of registration u/s 12A(1)(ac)(ii) and 80G of the

Income Tax Act, 1961 ('Act' for short) has been rejected.

2.

The Ld. Counsel for the Assessee submitted that the orders

impugned have been passed ex-parte, wherein Ld. CIT(E)has not

verified the documents produced by the Appellant and without

providing opportunity to the appellant to produce further documents

and submissions the orders impugned has been passed. Thus, sought

for allowing the Appeal.

2 ITA Nos. 615 & 614/Del/2026 Life Giving Word

3.

The Ld. Department's Representative vehemently submitted that

the appellant has failed to substantiate the claim in support of the

applications filed before the authority below, therefore, the

applications have been rightly rejected which requires no interference

at the hands of the Tribunal. Thus, relying on the orders of the Lower

Authority, sought for dismissal of the Appeals.

4.

We have heard both the parties and perused the material

available on record. It can be seen from the order impugned, the Ld.

CIT(E) has rejected the application on the ground that the applicant

has failed to file documentary evidences to enable me to satisfy about

the genuineness& commencement of its charitable activities and to

verify these activities are in consonance with its objects. Considering

the fact that the Assessee is claimed to be conducting charitable

activities, the Ld. CIT(E) should have provided opportunity to the

appellant to produce the documents and should have decided the

application on its merit. Thus, we set aside the impugned orders of

the Ld. CIT(E) and remand the matter to the file of Ld. CIT(E) with a

direction to decide the applications afresh after providing opportunity

of being heard to the Appellant. The Appellant is also at liberty to

produce all the requisite documents to substantiate the claim of the

Appellant.

3 ITA Nos. 615 & 614/Del/2026 Life Giving Word

5.

In the result, the appeals of the Assessee are partly allowed for

statistical purpose.

Order pronounced in the Open Court on this 27th Day of April, 2026

Sd/- Sd/- (SANJAY AWASTHI) (YOGESH KUMAR U.S.) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated: 27 /04/2026 R. Naheed *

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