SHRI MAHADEV AYURVEDIC CHARITABLE TRUST,MUMBAI vs. CIT (EXEMPTIONS), MUMBAI, MUMBAI

ITA 6938/MUM/2026Status: DisposedITAT Mumbai12 October 2026AY 2026-276 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the Learned CIT(E) had rejected the application for registration under Section 12AB without appreciating the submissions made by the assessee on February 6, 2026. The CIT(E) did not discuss these submissions in the impugned order, indicating that the rejection was made in ignorance of the examination of the written submission. The Tribunal also noted that the CIT(E) had not provided a sufficient and meaningful opportunity to the assessee during the proceedings. Consequently, the Tribunal restored the application for registration under Section 12AB to the file of the Learned CIT(E) for de novo adjudication. Regarding the rejection of the application under Section 80G, the Tribunal noted that it was rejected for the reason of the rejection of the Section 12AB application. Since the Section 12AB issue was remanded, the order rejecting the Section 80G application was also set aside and restored to the file of the Learned CIT(E) for fresh decision. The grounds raised by the assessee were allowed for statistical purposes.

What were the facts?

The Assessee, Shri Mahadev Ayurvedic Charitable Trust, filed appeals against two orders dated March 2, 2026, passed by the Learned Commissioner of Income Tax (Exemptions) (CIT(E)), Mumbai. These orders rejected the Trust's applications for renewal/approval under Section 12AB and Section 80G of the Income Tax Act, 1961. The rejection was primarily based on the grounds that the assessee failed to comply with a notice dated January 30, 2026, by not furnishing explanations and documents. The Assessee contended that they had indeed submitted a reply with complete documents on February 6, 2026, which was stamped by the CIT(E)'s office, but this submission was not considered by the CIT(E) in the impugned orders. The appeals were filed before the Income Tax Appellate Tribunal (ITAT), Mumbai Bench.

What were the issues?

1. Whether the Learned CIT(E) erred in rejecting the application for registration under Section 12AB of the Income Tax Act, 1961, without properly considering the submissions and documents placed on record by the assessee, specifically the reply dated February 6, 2026. Assessee's contention: The assessee argued that they had complied with the notice dated January 30, 2026, by furnishing a reply and complete documents on February 6, 2026, which was acknowledged by the CIT(E)'s office. However, the CIT(E) failed to consider this submission and incorrectly held that the assessee failed to furnish requisite details, leading to an arbitrary rejection. The assessee also submitted that a petition for reconsideration in Form 10AB was filed on March 16, 2026, which was also not considered. Revenue's contention: The departmental representative relied upon the order passed by the Learned CIT(E). 2. Whether the Learned CIT(E) erred in rejecting the application for approval under Section 80G of the Income Tax Act, 1961, solely on the grounds of rejection of registration under Section 12AB.

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, MUMBAI BENCH “D”, MUMBAI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI RAKESH KUMAR LODHA

For Appellant: Shri A.L Sharma
For Respondent: Shri Sandeep Lakra
Hearing: 24.09.2026Pronounced: 12.10.2026

PER : Shri Rakesh Kumar Lodha, Accountant Member:

These appeals have been filed by the Assessee against the order dated 2nd March, 2026, passed by the Learned Commissioner of Income tax (Exemptions), [“Ld. CIT (E)”] Mumbai, under Section 12AB(1)(b)(ii) and 80G of Income Tax Act, 1961 (“the Act”).

2.

The Assessee has raised the following grounds of appeals in ITA NO.6925/MUM/2026:

1.

(A) On the facts and circumstances of the case and in law, the learned CIT (Exemption) erred in rejecting the app

The order continues below.

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