ANTENNA TRUST,MADURAI vs. CIT EXEMPTIONS, CHENNAI

ITA 2897/CHNY/2026Status: DisposedITAT Chennai23 September 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E)'s order rejecting the assessee's application for registration under Section 12AB was not justified. The Tribunal observed that the CIT(E) had not made any discussion regarding the assessee's submissions but simply relied on the Supreme Court decision in New Noble Educational Society to reject the application. The Tribunal found this approach to be unjustified. Therefore, the Tribunal accepted the assessee's submission and remanded the matter back to the file of the CIT(E) for a fresh examination. The order of the CIT(E) was set aside, and the grounds raised by the assessee were allowed for statistical purposes. The Tribunal did not decide on the merits of the assessee's eligibility for registration but rather on the procedural deficiency in the CIT(E)'s order.

What were the facts?

The assessee, Antenna Trust, filed an appeal against the order dated 26.03.2026 passed by the Commissioner of Income Tax (Exemption), Chennai. The appeal was filed for an unspecified assessment year. The CIT(E) rejected the assessee's application seeking registration under Section 12AB of the Income Tax Act. The assessee's Authorized Representative (AR) requested one more opportunity to furnish details before the CIT(E), stating readiness to provide all necessary information. The Revenue's Representative (DR) opposed this request. The Tribunal noted that the CIT(E) relied on the Supreme Court decision in New Noble Educational Society to hold that the assessee's income was not eligible for exemption under Sections 11 & 12.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) was justified in rejecting the assessee's application for registration under Section 12AB of the Income Tax Act, 1961, without considering the assessee's submissions and by solely relying on the decision of the Hon'ble Supreme Court in New Noble Educational Society? Assessee's Contention: The assessee's AR argued that the order of the CIT(E) was not justified. The assessee requested one more opportunity to furnish all details before the CIT(E) and expressed readiness to do so. Revenue's Contention: The Ld. DR vehemently opposed the assessee's request for another opportunity.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 11,Section 12

AI-generated summary — verify with the full judgment below

Before: SHRI. INTURI RAMA RAO & BEFORE SHRI S.S. VISWANETHRA RAVI

Hearing: 09.09.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 26.03.2026 passed by the Commissioner of Income Tax (Exemption), Chennai.

2.

At the outset Ld. AR drew our attention to the para no.5 and submits that the order of CIT(E ) is not justified in holding the application of the assessee cannot be processed in view of discussion made therein above. The Ld. AR prayed for one more opportunity and the assessee is read

The order continues below.

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