SMT JANKI DEVI MANDELIA EDUCTAION SOCIETY ,PILANI JHUNJHUNU vs. COMMISSIONEER OF INCOME TAX(EXEMPTION), JAIPUR

ITA 1205/JPR/2026Status: DisposedITAT Jaipur23 September 2026AY 2026-20273 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that the assessee had filed a written application seeking withdrawal of the appeals. The reason provided for withdrawal was that the assessee trust's applications for registration under Section 12A and Section 80G, which were initially rejected, had subsequently been allowed by the Ld. CIT(Exemption) upon fresh applications. As a consequence, the appeals filed against the rejection orders were rendered infructuous. The revenue's representative (Ld. DR) did not object to the withdrawal. Therefore, the Tribunal held that the appeals filed by the assessee were dismissed as withdrawn. No specific finding was made on the merits of the original rejection orders, as the appeals were withdrawn due to subsequent events.

What were the facts?

The assessee, Smt Janki Devi Mandelia Education Society, filed appeals (ITA Nos. 1203 & 1205/JPR/2026) against separate orders passed by the CIT(E), Jaipur, dated 19.02.2026. These orders were passed under Section 12A and Section 80G of the Income Tax Act, 1961. The appeals pertained to the assessment year 2026-27. During the hearing on 23.09.2026, the assessee's counsel filed a written application seeking withdrawal of the appeals. The reason for withdrawal was that the assessee trust had reapplied for registration under Sections 12A and 80G after the initial rejection, and these applications were subsequently allowed by the Ld. CIT(Exemption). Consequently, the appeals filed against the rejection orders had become infructuous.

What were the issues?

1. Whether the assessee's appeals against the rejection of applications for registration under Section 12A and Section 80G of the Income Tax Act, 1961, have become infructuous, thereby warranting withdrawal. Assessee's Contention: The assessee argued that its applications for registration under Section 12A and Section 80G were initially rejected. However, the trust subsequently reapplied for registration, and these new applications were allowed by the Ld. CIT(Exemption). In light of the allowance of the fresh applications, the appeals filed against the earlier rejection orders have become infructuous, and therefore, the assessee wishes to withdraw the appeals. Revenue's Contention: The Ld. DR had no objection to the withdrawal of the appeals by the assessee.

Which sections of the Income-tax Act were involved?

Section 12A,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Before: SMT. ANNAPURNA GUPTA & SHRI T. R. SENTHIL KUMAR

Hearing: 23.09.2026Pronounced: 23.09.2026

Per Annapurna Gupta, AM:- The present appeal have been filed by the assessee against the separate orders passed by the CIT Exemption, Jaipur (hereinafter

P a g e | 2 ITA Nos. 1203 and 1205/JPR/2026 Smt Janki Devi Mandelia Education Society referred to as “Ld. CIT(E)”), dated 19.02.2026 respectively under Section 12A and 80G of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

2.

During the course of hearing before us, learned counsel for the assessee filed an application in writing seeking withdrawal of the appeal. The contents of the application read as under:-

The above noted appeal is

The order continues below.

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