SRI GOPALAKRISHNA TEMPLE TRUST,MANGLAORE vs. CIT(EXEMPTION), BANGLAORE

ITA 1772/BANG/2026Status: DisposedITAT Bangalore09 October 2026AY 2025-263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the learned CIT(E) rejected the application without issuing a notice to the assessee, providing an opportunity to be heard or to submit the required documents. The Tribunal found merit in the assessee's argument that an opportunity should be provided, especially for a charitable institution, in the interest of substantial justice. Following the principles of natural justice, the Tribunal remitted the matter back to the learned CIT(E) for fresh consideration of the application. The assessee was directed to submit the relevant documents without seeking unnecessary adjournments. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Sri Gopalakrishna Temple Trust, filed an application (Form 10AB) on 24.09.2025 seeking registration under Section 12AB of the Income Tax Act, 1961, for the Assessment Year 2025-26. The Commissioner of Income Tax (Exemptions) rejected the application via an order dated 10-Mar-2026, citing non-submission of complete details and documents. The assessee appealed this order, arguing that the CIT(E) did not provide an opportunity to furnish the required documents. The CIT(E) had not specified what further documents were needed, despite the assessee uploading various attachments. The CIT(E)'s order was based on the belief that the assessee failed to submit mandatory documents like the Trust deed, registration certificate, financial statements, audit reports, and proof of activities.

What were the issues?

1. Whether the learned CIT(E) erred in rejecting the assessee's application for registration under Section 12AB of the Income Tax Act, 1961, without providing an opportunity to furnish complete details and documents? (Question of law and fact, concerning Section 12AB). Assessee's contention: The assessee argued that the learned CIT(E) did not specify the exact documents required and that the assessee had uploaded various attachments. The assessee sought one more opportunity to furnish the necessary documents to support the registration application. Revenue's contention: The learned Departmental Representative relied on the order passed by the learned CIT(E).

Which sections of the Income-tax Act were involved?

Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI BALAKRISHNAN S & SHRI SOUNDARARAJAN K.

Pronounced: 09.10.2026

PER BALAKRISHNAN S, ACCOUNTANT MEMBER:

This appeal is filed by the Assessee against the rejection order of Ld. CIT(E) vide DIN: ITBA/EXM/F/EXM45/2025-26/1087129075(1) dated 10-Mar-2026 for the Assessment Year 2025-26 for the application seeking registration under section 12AB of the Act.

2.

Briefly stated, the facts of the case are assessee filed Form 10AB dated 24.09.2025 seeking registration under

The order continues below.

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