DR MPK HOMEOPATHIC MEDICAL COLLEGE HOSPITAL & RESEARCH CENTRE SOCIETY,JAIPUR vs. CIT EXEMPTION , JAIPUR

ITA 445/JPR/2026Status: DisposedITAT Jaipur30 September 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the denial of registration by the CIT(E) without considering the replies and documents filed by the assessee, specifically the e-acknowledgements dated 06.02.2026 and 10.02.2026, was against the Principle of Natural Justice. Therefore, the ITAT set aside the orders of the CIT(E) and remanded the matters back to the CIT(E)'s file. The CIT(E) was directed to provide one more opportunity of hearing to the assessee and then pass an order for registration under Section 12AB and Section 80G(5) of the Act, provided the assessee cooperates by filing all required documents and details. The ITAT allowed both appeals for statistical purposes.

What were the facts?

The assessee, DR MPK Homeopathic Medical College Hospital & Research Centre Society, filed two appeals before the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, challenging orders dated 12.02.2026 and 24.02.2026 passed by the Commissioner of Income Tax (Exemption) (CIT(E)), Jaipur. These orders denied the assessee registration under Section 12AB and Section 80G(5) of the Income Tax Act, 1961. This was the second round of proceedings before the CIT(E), as the ITAT had previously set aside the matter for the CIT(E) to consider necessary evidence. The CIT(E) provided two hearing opportunities but concluded that the assessee failed to furnish required details, leading to the denial of registration.

What were the issues?

1. Whether the denial of registration under Section 12AB and Section 80G(5) of the Income Tax Act, 1961, by the CIT(E) was justified, considering the documents submitted by the assessee? Assessee's Contention: The assessee argued that it had filed a Paper Book containing detailed replies, newspaper cuttings, Devasthan forms, University Act, fee structures, staff details, hospital requirements, MOA, and various fee ledgers, challans, and student fee details. The assessee requested the ITAT to set aside the matter back to the CIT(E) for consideration of these documents and grant of registration. Revenue's Contention: The Revenue, represented by the CIT-DR, had no objection to setting aside the matters back to the file of the CIT(E).

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH, JAIPUR

Before: Smt. Annapurna Gupta & Shri T. R. Senthil Kumar

For Appellant: Shri R. S. Poonia, CA
For Respondent: Shri Anil Dhaka, CIT

PER : T. R. SENTHIL KUMAR, JUDICIAL MEMBER:- These two appeals are filed by the assessee as against separate orders dated 12.02.2026 and 24.02.2026 passed by Ld. Commissioner of Income Tax (Exemption), Jaipur, denying the registration u/s. 12AB and 80G(5) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2.

This is the second round of registration before Ld. CIT(E) wherein in the first round, the Hon’ble ITAT set aside the matter back to the file

I.T.A No. 436 & 445/JPR/2026 Page No 2 DR MPK Homeopathic Medical College Hospital & Research Centre Society of Ld. CIT(

The order continues below.

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