BEST INDIA BUSINESS PROMOTION CENTRE,JAIPUR vs. CIT EXEMPTION, JAIPUR

ITA 717/JPR/2026Status: DisposedITAT Jaipur30 September 2026AY 2026-274 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the order passed by the CIT(E) was in gross violation of the principles of natural justice. The Tribunal noted that despite the assessee filing a letter on January 27, 2026, addressing all the deficiencies and providing the necessary information regarding its registrations under Section 12A and 80G, and its activities, the CIT(E) did not take cognizance of this reply. Furthermore, the CIT(E) rejected the application as deficient without issuing a show cause notice to the assessee, thereby denying them a proper opportunity of being heard. Consequently, the Tribunal restored the issue of grant of registration under Section 12AB back to the file of the CIT(E) to be considered afresh after affording due opportunity of hearing to the assessee. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Best India Business Promotion Centre, filed an appeal against the order of the CIT(Exemption), Jaipur, dated March 19, 2026. The CIT(E) had rejected the assessee's application for registration under Section 12AA of the Income Tax Act, 1961, for Assessment Year 2026-27. The rejection was based on the application being incomplete, specifically due to the non-furnishing of prior 12AA registration, a copy of registration under Section 12A(1)(ac)(i)/(iii) (mandatory for renewal of registration under Section 12A(1)(ac)(ii)), and a note on the applicant's activities. The assessee, though absent during the hearing, had filed a paper book. This paper book contained a letter dated January 27, 2026, addressed to the CIT(E), which purportedly addressed all the deficiencies noted by the CIT(E).

What were the issues?

1. Whether the order passed by the CIT(E) rejecting the assessee's application for registration under Section 12AA of the Income Tax Act, 1961, is valid, considering the alleged submission of all required documents by the assessee. Assessee's Contention: The assessee contended that all deficiencies noted by the CIT(E) were addressed in their letter dated January 27, 2026. This letter, filed in response to a notice dated January 20, 2026, stated that the assessee was registered under Section 12A with a unique registration number valid till AY 2026-27 and under Section 80G till AY 2028-29, and also provided a note on its activities. The assessee argued that the CIT(E) failed to consider this reply and rejected the application without issuing a proper show cause notice. Revenue's Contention: The revenue, represented by the CIT(E), argued that the application was incomplete due to the non-furnishing of specific documents as detailed in the order.

Which sections of the Income-tax Act were involved?

Section 12AA,Section 12A(1)(ac)(i),Section 12A(1)(ac)(ii),Section 12A(1)(ac)(iii),Section 80G,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 KUMAR

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 19.03.2026 for rejecting assessee’s application

P a g e | 2 Best India Business Promotion Centre seeking registration under Section 12AA of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for Assessment Year 2026-27. 2. Order of the ld. CIT(E) rejecting assessee’s application seeking registration u/s 12AA of the Act reveals that the same was rejected on account of incomplete form 10AB.

3.

The application filed by the assessee was noted to be incomplete on account of non-furnishing of the following documents:-  12AA registration prio

The order continues below.

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