SRI KAVERY KODAVA ASSOCIATION MYSURU EAST,MYSURU vs. COMMISSIONER OF INCOME-TAX (EXEMPTIONS), BENGALURU

ITA 748/BANG/2026Status: DisposedITAT Chennai24 September 2026AY 2026-277 pages
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What did the Tribunal hold?

The Tribunal admitted the additional evidence filed by the assessee under Rule 29 of the Income-Tax (Appellate Tribunal) Rules, 1963, finding good and sufficient reason as the evidence was considered essential for adjudicating the issue. The Tribunal noted that the CIT(Exemptions) had rejected the applications for registration under Section 12AB and approval under Section 80G solely on the ground that the assessee had not responded to notices and failed to submit necessary documents. However, the assessee contended that it had appeared and submitted documents which were not recorded in the impugned order. In the interest of justice, equity, and fair play, the Tribunal deemed it fit to remit the entire issue of registration under Section 12AB and approval under Section 80G back to the file of the CIT(Exemptions) for a fresh decision in accordance with the law. The CIT(Exemptions) was directed to grant a reasonable opportunity of being heard to the assessee, and the assessee was directed to submit all additional evidence produced before the Tribunal, along with any other required documents, to the CIT(Exemptions).

What were the facts?

The assessee, Sri Kaveri Kodava Association, filed applications for registration under Section 12AB and approval under Section 80G of the Income Tax Act, 1961. The Commissioner of Income-tax (Exemptions), Bengaluru, rejected both applications by orders dated 19.12.2025. The assessee appealed these orders to the Income Tax Appellate Tribunal (ITAT), Bangalore Bench. The primary reason for rejection by the CIT(E) was the assessee's alleged failure to respond to notices and submit necessary documents. The assessee, however, contended that it had appeared before the CIT(E) and submitted the required documents, which were not recorded in the impugned orders, leading to prejudice. The assessee also filed an application for admission of additional evidence before the ITAT.

What were the issues?

1. Whether the orders dated 19.12.2025 passed by the learned CIT(Exemptions), Bengaluru, rejecting the application for registration under Section 12AB of the Income Tax Act, 1961, are bad and erroneous, and against the facts and circumstances of the case, particularly in light of the alleged violation of principles of natural justice and failure to consider submitted documents. 2. Whether the orders dated 19.12.2025 passed by the learned CIT(Exemptions), Bengaluru, rejecting the application for approval under Section 80G of the Income Tax Act, 1961, are bad and erroneous, and against the facts and circumstances of the case, particularly in light of the alleged violation of principles of natural justice and failure to consider submitted documents. Assessee's Contentions: The assessee argued that the CIT(E) passed ex-parte orders rejecting the applications without providing an effective hearing, thus violating principles of natural justice. It was also contended that the applications were rejected without a finding on merit and without considering the documents submitted. The assessee claimed eligibility for both registration under Section 12AB and approval under Section 80G. Revenue's Contentions: The judgment does not record specific contentions made by the revenue before the Tribunal.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

Hearing: 29.07.2026Pronounced: 24.09.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

These appeals at the instance of the assessee are directed against the orders of the ld.CIT (Exemptions), Bengaluru both dated 19.12.2025 vide DIN & Notice No. ITBA/EXM/F/EXM45/2025- 26/1083865783(1) rejecting the application filed for registration u/s 12AB of the Income Tax Act, 1961 (in short “the Act”) and vide DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/1083865793(1) rejecting the approval u/s 80G of the Act.

2.

The assessee has raised the following grounds of appeal in ITA No.748/Bang/2026:-

1.

The ex-parte order dated 19.12.2025 passed by the learned

The order continues below.

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