SHRI DIGAMBER JAIN MANDIR SAMITI,KOTA vs. CIT EXEMPTION, JAIPUR

ITA 1043/JPR/2026Status: DisposedITAT Jaipur30 September 2026AY 2026-273 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(E) had not provided sufficient opportunity of hearing to the assessee before rejecting the application for registration under Section 12A. The order was passed ex parte after only one opportunity was given. In the interest of justice, the Tribunal decided that the assessee's application should be reconsidered by the CIT(E) after giving a due opportunity of hearing. The Ld. DR also agreed to this course of action. Consequently, the application was restored back to the CIT(E) for fresh consideration. The appeal was allowed for statistical purposes. No specific issue was left undecided.

What were the facts?

The assessee, Shri Digamber Jain Mandir Samiti, filed an appeal against the order of the CIT(E), Jaipur, dated 19.03.2026. The CIT(E) rejected the assessee's application for registration under Section 12A of the Income Tax Act, 1961. The rejection was based on two grounds: the assessee was not registered under the Rajasthan Public Trust Act, 1959, and the application form 10AB was incomplete. The incomplete form was attributed to the non-furnishing of documents related to prior 12AA registration, which was the basis for obtaining registration under Section 12A(1)(ac)(i) from the CPC. The CIT(E) passed an ex parte order after providing only one opportunity for hearing. The Tribunal noted that sufficient opportunity was not given to the assessee.

What were the issues?

1. Whether the CIT(E) erred in rejecting the assessee's application for registration under Section 12A of the Income Tax Act, 1961, on the grounds of non-registration under the Rajasthan Public Trust Act, 1959, and incomplete form 10AB, without affording sufficient opportunity of hearing to the assessee? Assessee's Contentions: The assessee contended that the CIT(E) rejected their application for registration under Section 12A without providing adequate opportunity for hearing. The application was rejected ex parte after only one opportunity was given. Revenue's Contentions: The Revenue, through the Ld. DR, fairly agreed to the assessee's contention regarding the lack of sufficient opportunity for hearing.

Which sections of the Income-tax Act were involved?

Section 12A,Section 12A(1)(ac)(i),Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI T. R. SENTHIL KUMARShri Digamber Jain Mandir

Hearing: 23.09.2026Pronounced: 30.09.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the CIT Exemption Jaipur(hereinafter referred to as “Ld. CIT(E)”), dated 19.03.2026for rejecting assessee’s application

P a g e | 2 Shri Digamber Jani Mandir Samiti seeking registration under Section 12A of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

2.

Order of the ld. CIT(E) rejecting assessee’s application seeking registration u/s 12AB of the Act reveals that the same was rejected for the reason that the assessee was not registered under the Rajasthan Public Trust Act 1959 (in short “RPT”) and on account of incomplete form 10AB.

3.

The application filed by the assessee was noted to be incomplet

The order continues below.

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