BIBI KAULAN JI ASEES SANGAT NIWAS TRUST,AMRITSAR vs. THE COMMISSIONER OF INCOME-TAX (EXEMPTIONS), CHANDIGARH

ITA 901/ASR/2026Status: DisposedITAT Amritsar29 September 2026AY 2026-20274 pages
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What did the Tribunal hold?

The Tribunal held that the rejection of the application for registration under Section 12AB was principally for the reason that requisite documents/details were not furnished, despite the deficiency having been pointed out. The rejection was essentially founded upon non-compliance and procedural deficiencies. The Tribunal was of the considered opinion that the matter deserved to be examined afresh by the CIT(E), rather than the assessee being foreclosed from consideration of its claim for registration merely on account of these deficiencies. Accordingly, in the interest of justice and fair play, the Tribunal set aside the impugned order and restored the application for registration to the file of the CIT(E) for consideration and adjudication afresh in accordance with law. The assessee was directed to furnish all requisite documents, information, and explanations. The CIT(E) was directed to afford a reasonable opportunity of being heard and decide the application afresh on merits. The Tribunal clarified that it had not expressed any opinion on the merits of the assessee’s eligibility for registration. The second appeal regarding the rejection of the application for approval under Section 80G(5) was consequential to the rejection of registration under Section 12AB. Since the matter relating to registration was restored, the appeal relating to Section 80G also met the same fate.

What were the facts?

The assessee, Bibi Kaulan Ji Asees Sangat Niwas Trust, filed appeals before the Income Tax Appellate Tribunal (ITAT) against the order of the Commissioner of Income Tax (Exemption) [CIT(E)], Chandigarh. The CIT(E) had rejected the assessee's applications for registration under Section 12A(1)(ac)(iii) and approval under Section 80G of the Income-tax Act, 1961, for the assessment year 2026-27. The rejection was based on the CIT(E)'s observation that the assessee failed to submit a reply to a show cause notice and sought an adjournment, despite being afforded an opportunity to furnish details and documents. The CIT(E) concluded that the application was deficient in terms of required submissions regarding charitable objects and genuineness of activities. The assessee contended that it had filed a comprehensive reply with necessary documents, and the rejection was due to procedural deficiencies rather than adverse findings on merits.

What were the issues?

1. Whether the rejection of the application for registration under Section 12AB of the Income-tax Act, 1961, by the CIT(E) was justified on account of procedural deficiencies and non-furnishing of certain documents, without examining the merits of the charitable objects and genuineness of activities of the assessee trust? Assessee's Contentions: The assessee argued that it had filed a comprehensive reply dated 28.04.2026, enclosing copies of the trust deed, registration certificate, provisional registration order, provisional approval under Section 80G, and detailed explanations for every query raised in the first notice. The assessee contended that the CIT(E) failed to examine the merits of the case despite the requisite details being furnished. The rejection, according to the assessee, was essentially on account of procedural deficiencies and non-furnishing of certain documents, not on any adverse finding regarding the charitable objects or genuineness of its activities. Revenue's Contentions: The judgment records that the appellant (assessee) was represented by 'None' and the respondent (revenue) was represented by Sh. Jivandeep Singh Kahlon, CIT. DR. No specific arguments for the revenue are recorded in the provided text, other than the CIT(E)'s order which formed the basis of the appeal.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 80G,Section 12AB,Section 12AB(1)(b)(ii),Section 80G(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR

Before: SH. SAKTIJIT DEY, HON’BLE & SH. GIRISH AGRAWAL, HON’BLE

Hearing: 29.09.2026Pronounced: 29.09.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These two appeals are filed by the assessee against the order of the Ld. CIT (E), Chandigarh, dated 29.06.2026, rejecting the application seeking registration u/s 12A(1)(ac)(iii) and approval u/s 80G of the Income-tax Act, 1961 (henceforth the Act).

2.

We take up appeal for rejection of application seeking registration u/s 12AB where the ld. CIT(E) observed that assessee did not submit any reply called for and I.T.A. No.890 and 901/Asr/2026 Bibi Kaulan Ji Asees Sangat Niwas Trust 2 Assessment Year: 2026-27 sought an adjournment pursuant to the show cause notice issued by him. According to the ld. CIT(E), in spite of opportunity a

The order continues below.

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