SANJIV BANSAL CHARITABLE TRUST,KARNAL vs. COMMISSIONER OF INCOME TAX EXEMPTION , CHANDIGARH

1 ITA No.172/Chandi/2026 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI RAJPAL YADAV, VICE PRESIDENT AND HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकर अपील सं./ ITA No.172/CHANDI/2026 Sanjiv Bansal Charitable Trust CIT(E) Sanjiv Hospital, Railway Road CR Building, Sector – 17, बनाम/ Vs. Karnal - 132001 Chandigarh - 160017 �ायीलेखासं./जीआइआरसं./PAN/GIR No. AAATS-5445-H (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : Shri Satish Kumar Goyal (Advocate) – Ld. AR ��थ�कीओरसे/Respondent by : Smt. Kusum Bansal (CIT) - Ld. DR सुनवाईकीतारीख/Date of Hearing : 22-04-2026 घोषणाकीतारीख /Date of Pronouncement : 22-04-2026 आदेश / O R D E R Manoj Kumar Aggarwal (Accountant Member) 1. Aggrieved by rejection of an application seeking registration u/s 12A(1)(ac)(ii) vide impugned order dated 30-12-2025 of Ld. Commissioner of Income Tax (Exemption), Chandigarh, [CIT(E)], the assessee is in further appeal before us. 2. Upon perusal of paras 3.3 & 3.4 of the impugned order, it could be seen that the registration has been denied to the assessee on the ground that the major portion of application of income was donations to other institutions. No evidence was furnished to establish that the

2 ITA No.172/Chandi/2026 recipient institutions had similar objects. Further, the assessee was primarily engaged in earning rental income from commercial leasing of its property. The assessee did not carry out any charitable activities. 3. The Ld. AR stated that during proceedings, only one questionnaire was issued by Ld. CIT(E) on 08-11-2025 which was duly been responded to by the assessee on 24-11-2025. The impugned findings were never confronted to the assessee. The Ld. AR drew attention to Page Nos. 176 to 183 of the paper-book to contend that complete details of recipient institutions is available with the assessee. The Ld. AR also argued that the proviso to Sec. 2(15) may not be applicable to the assessee. The Ld. CIT-DR opposed any interference in the impugned order. 4. Considering the fact that the grounds on which the application has been rejected were not effectively confronted to the assessee, we set aside the impugned order and restore the issue of registration back to the file of Ld. CIT(E) for fresh consideration with a direction to the assessee to establish its case. 5 The appeal stand allowed for statistical purposes. Order pronounced on 22nd April, 2026.

Sd/- Sd/- (RAJPAL YADAV) (MANOJ KUMAR AGGARWAL) VICE PRESIDENT ACCOUNTANT MEMBER

Dated: 22-04-2026

3 ITA No.172/Chandi/2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF ASSISTANT REGISTRAR ITAT CHANDIGARH