SHREE JAIN SHWETHAMBER MURTHI PUJAK TRUST,CHENNAI vs. CIT(EXEMPTION), CHENNAI

ITA 3555/CHNY/2026Status: DisposedITAT Chennai23 September 20263 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the matter was disposed of in an ex-parte manner by the Commissioner. Therefore, the Tribunal restored the matter back to the file of the Ld. CIT(E), Chennai, for reconsideration. The assessee was directed to provide the relevant documents and cooperate with the proceedings. The Tribunal emphasized that its endeavor is always to adjudicate matters on a substantive basis. In view of these directions, the grounds raised by the assessee were allowed for statistical purposes only. The appeal was allowed for statistical purposes only, with condonation of delay based on an affidavit and application filed before the Tribunal.

What were the facts?

The assessee, Shree Jain Shwethamber Murthi Pujak Trust, filed an appeal against the order of the Commissioner of Income Tax (Exemption), Chennai, dated 23.03.2026. The appeal challenges the rejection of the assessee's application filed in Form No. 10AB on 29.09.2025, seeking registration under Section 12AB of the Income Tax Act, 1961. The Commissioner rejected the application because the assessee failed to provide the trust deed, the approval under Section 12AA obtained prior to 01.04.2021, and the financial statements for the financial year 2024-25. The matter was disposed of ex-parte.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) erred in rejecting the application for registration under Section 12AB of the Income Tax Act, 1961, on the grounds of non-submission of required documents. Assessee's Contention: The assessee argued that the Commissioner erred in rejecting the application and failed to appreciate that the appellant is eligible for and has satisfied all conditions for obtaining registration under Section 12AB. The grounds of appeal also state the order is contrary to law, facts, and principles of natural justice. Revenue's Contention: The judgment does not record any specific contentions made by the Revenue. However, the Commissioner's order, which is under challenge, rejected the application due to the non-furnishing of the trust deed, prior 12AA registration certificate, and financial statements for FY 2024-25.

Which sections of the Income-tax Act were involved?

Section 12A (1) (ac) (ii),Section 12AB,Section 12AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HONOURABLE GEORGE GEORGE K & SHRI GAGAN GOYAL

Hearing: 25.08.2026Pronounced: 23.09.2026

PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of Ld. Commissioner of Income Tax (E), (hereinafter referred to as the ‘Ld. CIT (E)’), Chennai dated 23.03.2026. GROUDS OF APPEAL

1.

For that the order of the Commissioner of Income Tax (Exemption), Chennai is contrary to law, facts and circumstances of the case and is opposed to the principles of natural justice, equity and

The order continues below.

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