V S JAIN CHARITABLE TRUST,HARYANA vs. CIT EXEMPTIONS, CHANDIGARH

ITA 3057/DEL/2026Status: DisposedITAT Delhi25 September 20264 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the right to a reasonable opportunity of being heard is a fundamental right of every taxpayer. It noted that the CIT(E) had rejected the assessee's applications for registration under section 12A and 80G on the premise of non-supply of requisite documents and a perceived failure to substantively reply to show cause notices regarding the genuineness of charitable activities. The Tribunal found that the CIT(E) had rejected the applications without due consideration of facts and alluded to a non-application of mind. In the interest of justice, the Tribunal set aside the impugned orders of the CIT(E) and remitted the matters back to the CIT(E) for de novo adjudication. The assessee was directed to comply with all statutory notices, with non-compliance to be viewed adversely. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, V S Jain Charitable Trust, filed two appeals before the Income Tax Appellate Tribunal (ITAT), Delhi Bench, against orders dated 13.03.2026 passed by the Commissioner of Income Tax (Exemption), Chandigarh (CIT(E)). ITA No. 3056/Del/2026 pertains to the rejection of the assessee's request for registration under section 12A(1)(ac)(ii) of the Income Tax Act, 1961. ITA No. 3057/Del/2026 concerns the rejection of its request under section 80G(5)(ii) of the Act. Both appeals were heard together. The CIT(E) rejected the applications, stating that the assessee failed to provide a substantive reply explaining how its financial statements constituted charitable activities or demonstrated actual charitable work over a prolonged period. The assessee contended that its right to natural justice was violated due to a lack of due opportunity to be heard.

What were the issues?

1. Whether the assessee's right to natural justice was violated by the CIT(E) in rejecting its applications for registration under section 12A(1)(ac)(ii) and 80G(5)(ii) of the Income Tax Act, 1961, without providing a due opportunity of being heard? The assessee argued that its right to natural justice was violated, as it was not given a proper opportunity to be heard before the rejection of its applications for registration under sections 12A and 80G. The assessee requested one last chance to defend its case and for the matter to be remitted back to the CIT(E), assuring full compliance with statutory notices. The revenue, through the CIT(DR), relied upon the orders of the lower authorities.

Which sections of the Income-tax Act were involved?

Section 12AB(1)(b)(ii),Section 80G,Section 12A(1)(ac)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI

Before: MS. KAVITHA RAJAGOPAL

Pronounced: 15.07.2026

PER AMITABH SHUKLA, AM These two appeals by the assessee are directed against the orders of the Ld.

Commissioner of Income Tax (Exemption), Chandigarh, [hereinafter referred to as ‘ld. CIT(E)] both dated 13.03.2026 passed under section 12AB(1)(b)(ii) and 80G of the Income Tax Act, 1961. The word ‘Act’ herein this order would mean Income Tax Act, 1961. 2. The appeal of the assessee vides ITA No.3056/Del/2026 is regarding the rejection of its request filed under section 12A(1)(ac)(ii) of the Act. T

The order continues below.

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