RAJNANDGAON LEPROSY HOSPITAL & CLINIC, RAJNANDGAON,RAJNANDGAON vs. EXEMEPTION WARD 2 RAIPUR, RAIPUR

ITA 373/RPR/2026Status: DisposedITAT Raipur13 October 2026AY 2027-285 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the order of the Ld. CIT(Exemption) rejecting the renewal of registration under Section 12A of the Income Tax Act, 1961, was set aside. The matter was remanded back to the file of the Ld. CIT(Exemption) with a direction to grant the assessee a final opportunity to comply with the hearing notices and represent its case on merits under Section 12AB of the Act. The Tribunal emphasized the importance of adhering to the principles of natural justice and noted that the Revenue had not brought on record any evidence of deliberate or willful negligence by the assessee. Furthermore, the Tribunal observed that the allegations regarding conversion, which led to the cancellation of the assessee's FCRA registration, were sub-judice before the Hon'ble Jurisdictional High Court. Therefore, it would be appropriate for the Ld. CIT(Exemption) to await the outcome of the High Court's decision before proceeding with the matter concerning Section 12AB of the Act. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Rajnandgaon Leprosy Hospital & Clinic, filed an appeal against the order of the Ld. CIT(Exemption), Bhopal, dated 28.03.2026, for Assessment Year 2027-28. The Ld. CIT(Exemption) had rejected the assessee's application for renewal of registration under Section 12A of the Income Tax Act, 1961. This rejection was based on information received from the Central Security Agency indicating that the assessee-NGO was allegedly providing treatment to sick people and attempting to convert them to Christianity. The assessee failed to comply with the show cause notices issued by the Ld. CIT(Exemption) regarding these allegations. The appeal was heard by the ITAT Raipur Bench.

What were the issues?

1. Whether the Ld. CIT(Exemption) was justified in rejecting the assessee's application for renewal of registration under Section 12A of the Income Tax Act, 1961, without providing a final opportunity to the assessee, thereby violating principles of natural justice? Assessee's Contention: The assessee contended that the rejection of their registration renewal application was against the principles of natural justice, as they were not given a final opportunity to present their case. They also highlighted that the allegations leading to the cancellation of their FCRA registration, which formed the basis for the show cause notice, were pending adjudication before the Hon'ble Jurisdictional High Court. Revenue's Contention: The revenue, through the Ld. CIT(Exemption), rejected the application for renewal of registration due to the assessee's failure to comply with notices and the alleged activities of conversion, which were also the reason for the cancellation of their FCRA registration.

Which sections of the Income-tax Act were involved?

Section 12A,Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “DB”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY & SHRI AVDHESH KUMAR MISHRA

For Appellant: Shri R.B Doshi, CA
For Respondent: Shri Rituparna Namdeo, CIT-DR
Hearing: 09.10.2026Pronounced: 13.10.2026

PER PARTHA SARATHI CHAUDHURY, JM: The present appeal preferred by the assessee emanates from the order of the Ld. CIT(Exemption), Bhopal dated 28.03.2026 for the assessment year 2027-28 as per the grounds of appeal on record.

2.

In this case, it was observed by the Ld. CIT(Exemption) that as per information available with his office, FCRA registration of the assessee had been cancelled through information by the C

The order continues below.

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