JOHN AND MARIE ALMEIDA EDUCATIONAL TRUST,CHENNAI vs. CIT EXEMPTIONS,, CHENNAI

ITA 3672/CHNY/2026Status: DisposedITAT Chennai23 September 20263 pages
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What did the Tribunal hold?

The Tribunal held that the order under consideration was passed in an ex-parte manner due to a communication gap between the office of the Ld. CIT(E) and the assessee, specifically because the show cause notice was sent to a wrong email ID. The Tribunal found that there was no effective service of the SCN as per the provisions of section 282 of the Income-Tax Act, 1961. Therefore, the matter was restored back to the office of the Ld. CIT(E) with a direction to reconsider the application after giving the assessee a proper opportunity of being heard. The assessee was directed to comply with the notices issued by the Ld. CIT(E) and participate in the proceedings. The grounds raised by the assessee were allowed for statistical purposes only. The ITAT did not decide on the merits of the application for registration itself.

What were the facts?

The assessee, John and Marie Almeida Educational Trust, filed an online application on September 29, 2025, in Form No. 10AB seeking registration under section 12AB of the Income-Tax Act, 1961. The trust had provisional registration for Assessment Years 2022-23 to 2026-27. The Commissioner of Income Tax (Exemptions), Chennai (Ld. CIT(E)), issued a Show Cause Notice (SCN) on February 7, 2026, due to perceived irregularities. However, this SCN was sent to an incorrect email address (rengarajanhr@gmail.com) instead of the assessee's registered emails. Consequently, the assessee did not receive the SCN and could not respond. The Ld. CIT(E) passed an ex-parte order dated March 31, 2026, rejecting the application. The assessee appealed this order to the Income Tax Appellate Tribunal (ITAT), Chennai.

What were the issues?

1. Whether the order of the Ld. CIT(E) dated March 31, 2026, rejecting the assessee's application for registration under section 12AB of the Income-Tax Act, 1961, is erroneous, bad in law, and passed ignoring the facts and merits of the case? 2. Whether the Ld. CIT(E) failed to appreciate that the show cause notice dated February 7, 2026, was not sent to the assessee's registered email addresses, thus constituting a failure to provide effective service as per section 282 of the Act? 3. Whether the Ld. CIT(E) ought to have rejected the appellant's application for registration under section 12A(1)(ac)(ii) without affording a proper opportunity of hearing? Assessee's Contentions: - The Ld. CIT(E)'s order is erroneous and passed ignoring facts and merits. - The show cause notice was not sent to the correct email addresses, meaning there was no effective service under section 282 of the Act. - The application was rejected without affording a proper opportunity of hearing. Revenue's Contentions: - The judgment records no specific contentions for the revenue.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 282,Section 12A(1)(ac)(ii)

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 as the ‘Ld. CIT (E)’), Chennai dated 31.03.2026. GROUDS OF APPEAL A.

For that the order of the Ld. Commissioner of Income-Tax (Exemptions) Chennai, [CIT (E)] under section 12AB of the Income-Tax Act, 1961 (Act) dated 31.03.2026 is er

The order continues below.

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