IQRA EDUCATIONAL AND CHARITABLE TRUST,CHENNAI vs. JURISDICTIONAL ASSESSING OFFICER - NON CORP.WARD 1(2) CHE, CHENNAI

ITA 1083/CHNY/2026Status: DisposedITAT Chennai07 October 2026AY 2018-195 pages
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What did the Tribunal hold?

The Tribunal condoned the delay of 270 days in filing the appeals, finding sufficient cause due to a change in management and the process of compiling records. Regarding the dismissal by the CIT(A) for non-prosecution, the Tribunal noted that the assessee failed to participate before the first appellate authority. However, to meet the ends of justice, the Tribunal set aside the orders of the CIT(A) and restored the matters to the file of the Jurisdictional Assessing Officer (JAO). The JAO was directed to verify the expenditure incurred by the assessee for its educational activities and allow admissible expenditure. The taxable income was to be determined after giving the assessee an opportunity to be heard and furnish necessary details and supporting evidence. The Tribunal also levied a cost of Rs. 10,000/- (Rs. 5,000/- for each appeal) to be paid to the State Legal Aid Authority, High Court of Madras, within 30 days. The appeals were allowed for statistical purposes.

What were the facts?

The assessee, IQRA EDUCATIONAL AND CHARITABLE TRUST, filed appeals against orders of the CIT(A) which dismissed its appeals against intimation orders passed by CPC, Bengaluru under Section 143(1) for Assessment Years 2018-19 and 2019-20. The CPC had disallowed deductions claimed by the trust, leading to demands of Rs. 15,58,203/- for AY 2018-19 and Rs. 18,24,535/- for AY 2019-20. The assessee's appeals before the CIT(A) were dismissed for non-prosecution, despite the CIT(A) providing multiple opportunities for hearings. The assessee then filed appeals before the ITAT, admitting a delay of 270 days, which was condoned due to a change in management and the process of collating records.

What were the issues?

1. Whether the delay of 270 days in filing the appeals before the Tribunal should be condoned? (Question of fact) 2. Whether the CIT(A) erred in dismissing the appeals for non-prosecution without considering the assessee's contention that notices should not be sent by email and that filing of a wrong return form (ITR-7 instead of ITR-5) is a procedural defect that should not defeat a substantive claim, especially when no prejudice is caused to the revenue? (Question of law and fact) Assessee's arguments: - The delay in filing the appeals was due to a change in management and the time taken to compile records, constituting sufficient cause. - The CIT(A) erred by sending hearing notices via email, contrary to the assessee's stated preference. - Dismissing the appeals solely for filing in ITR-7 instead of ITR-5 was incorrect, as it is a procedural defect and all relevant particulars were disclosed without claiming exemptions under Sections 11 or 12. - The assessee prayed for setting aside the CIT(A) orders and remitting the issues to the AO for a fresh opportunity. Revenue's arguments: - The CIT(A) provided sufficient opportunities, but the assessee was negligent in responding to notices. - The orders of the CIT(A) should be confirmed.

Which sections of the Income-tax Act were involved?

Section 143(1),Section 11,Section 12

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI S.R. RAGHUNATHA

Hearing: 08.09.2026Pronounced: 07.10.2026

PER S.R.RAGHUNATHA, AM:

These two appeals of the assessee are filed against the separate orders dated 21.03.2025 passed by the learned Commissioner of Income Tax (Appeals), Addl/JCIT(A)-1, Hyderabad (in short ‘ld.CIT(A)’), dismissing the appeals filed by the assessee against the intimation orders passed by the CPC, Bengaluru u/s.143(1) of the Income Tax Act, 1961 (in short ‘the Act’) dated

:-2-: I

The order continues below.

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