VIDYA BHARTI INSTITUTE OF TRAINING AND RESEARCH TRUST, KURUKSHETRA,KURUKSHETRA vs. CIT EXEMPTIONS CHANDIAGRH, CHANDIGARH

ITA 6591/DEL/2026Status: DisposedITAT Delhi29 September 2026AY 2026-20273 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal decided that the delay of 194 days in filing the appeals should be condoned. The Tribunal reasoned that the assessee's explanation for the delay, which was an attempt to refile the applications afresh, was acceptable. Regarding the merits, the Tribunal held that the rejection of registration and cancellation of approval due to the inadvertent mention of the wrong provision of law in the online application was a technical glitch that should not prejudice the assessee's substantial rights. The Tribunal was of the considered view that the ends of justice required giving the assessee an opportunity to contest on merits. Therefore, the issue on the merits of the assessee's claim was restored to the file of the CIT(A) with a direction to allow the assessee to revise its application, mentioning the correct provision of law under which it intended to seek registration and corresponding approval. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, Vidya Bharti Institute of Training and Research Trust, filed appeals against an order dated 22.09.2025 passed by the CIT(Exemption), Chandigarh. This order rejected the assessee's application for registration and cancelled its approval under Section 12A(1)(ac)(vi) and Section 80G of the Income Tax Act, 1961, for the Assessment Year 2026-27. The appeals were filed with a delay of 194 days. The assessee sought condonation of this delay, citing an attempt to refile the applications afresh as the reason. The Tribunal condoned the delay and admitted the appeals for hearing.

What were the issues?

1. Whether the delay of 194 days in filing the appeals should be condoned? (Question of fact) 2. Whether the rejection of registration and cancellation of approval under Section 12A(1)(ac)(vi) and Section 80G was justified due to a technical glitch in mentioning the incorrect provision of law in the online application? (Question of mixed law and fact, turning on Section 12A(1)(ac)(vi) and Section 80G). Assessee's Contentions: The assessee argued that the delay was due to an attempt to refile the applications afresh. The assessee also contended that the rejection of registration and approval was due to an inadvertent error in mentioning the correct provision of law in the online application, and this technical glitch should not prejudice its substantial rights. The assessee sought an opportunity to contest on merits. Revenue's Contentions: The judgment records no specific contentions from the revenue regarding the merits of the case or the delay.

Which sections of the Income-tax Act were involved?

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

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCHES, NEW DELHI

Before: SHRI ANUBHAV SHARMA & SHRI MANISH AGARWAL

For Respondent: Ms. Rakhi Vimal, CIT, DR
Pronounced: 24.09.2026

PER SHRI ANUBHAV SHARMA, JUDICIAL MEMBER:

These appeals filed by the assesse against the order dated 22.09.2025 passed by the Ld. CIT(Exemption),Chandigarh (for short “Competent Authority”) against the rejection of registration and consequent c

The order continues below.

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