PRAGATHI HOSPITAL EDUCATION TRUST,DAKSHIN KANNADA vs. THE COMMISSIONER OF INCOME TAX,(EXEMPTIONS),BANGALORE, BANGALORE.

ITA 1419/BANG/2026Status: DisposedITAT Bangalore05 October 2026AY 2026-273 pages

AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the Commissioner of Income Tax (Exemptions) had dismissed the assessee's appeals for want of documents. However, the facts indicated that the assessee had furnished the requisite documents, as evidenced by page 26 of the paper book. Therefore, in the interest of justice and fair play, the Tribunal decided to set aside the issue to the CIT(E) for fresh adjudication in accordance with the law. The assessee was granted liberty to furnish any additional documents if desired by the CIT(E) and was directed to cooperate with the proceedings and avoid unnecessary adjournments. The grounds of appeal were allowed for statistical purposes.

What were the facts?

The assessee, Pragathi Hospital Education Trust, filed two appeals (ITA Nos. 1418 & 1419/BANG/2026) before the Income Tax Appellate Tribunal (ITAT), Bangalore Bench, against the order of the Commissioner of Income Tax (Exemptions), Bangalore, for Assessment Year 2026-27. The appeals challenged the CIT(E)'s order dated March 10, 2026, which dismissed the assessee's earlier appeals for want of documents. The assessee's representative stated that all necessary documents were submitted to the CIT(E) by February 7, 2026, as per the CIT(E)'s letter, and requested the matter be set aside to the CIT(E) for fresh adjudication. The Revenue's representative raised no objection to this request.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemptions) erred in dismissing the assessee's appeals for want of documents, despite the assessee claiming to have submitted all necessary documents? (Question of mixed law and fact, concerning principles of natural justice and procedural fairness under the Income Tax Act, 1961). Assessee's Contention: The assessee argued that it had furnished all the documents requested by the CIT(E) vide letter dated February 7, 2026, and that the CIT(E) had dismissed the appeals without considering these documents. The assessee prayed for the matter to be set aside to the CIT(E) for fresh adjudication, assuring cooperation and willingness to provide any further documents required. Revenue's Contention: The Revenue did not raise any objection to the restoration of the appeals to the file of the CIT(E).

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, BANGALORE BENCHES, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SANDEEP SINGH KARHAIL

For Respondent: Shri N.S Shashidhara, CIT

आयकर अपीलीय अधिकरण, बेंगलुरू पीठें, बेंगलुरू INCOME TAX APPELLATE TRIBUNAL, BANGALORE BENCHES, BANGALORE BENCH: B

BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER

ITA Nos.1418 & 1419/BANG/2026 (निर्धारण वर्ा/Assessment Year: 2026-27) PRAGATHI HOSPITAL THE COMMISSIONER OF EDUCATION TRUST INCOME TAX,(EXEMPTIONS), PRAGATHI HOSPITAL, MAIN ROAD, BANGALORE. BOLWAR,PUTTUR,DAKSHINA KANNADA-574201, PUTTUR- UNITY BUILDING ANNEX, Vs. 574201, KARNATAKA MISSION ROAD,BANGALORE - 560027 BENGALURU-560027, KARNATAKA अपीलधर्थी Appellant प्रत्यर्थी Respondent

Permanent Account Number of Assessee: AADTP2008C

अपीलधर्थी द्वारा/Appellant represented by: Ms. Ema Bindu SV, Advocate प्रत्यर्थी द्वारा/Respondent represented by: Shri N.S Shashidhara, CIT

सुनवाई की तारीख / Date of conclusion of hearing: 30-Sept-2026 घोषणा की तारीख / Date of pronouncement: 05-Oct-2026 आदेश / ORDER PER SHRI WASEEM AHMED, ACCOUNTANT MEMBER:

These two appeals are filed by the Assessee against the order of Ld. Commissioner of Income Tax (Exemptions), Bangalore vide DIN: ITBA/EXM/F/EXM45/2025-26/1087131686(1) and DIN & Notice No: ITBA/EXM/F/EXM45/2025- 26/1087131496(1) dated 10-Mar-2026 for the Assessment Year 2026-27.

ITA 1418 & 1419/BANG/2026 PRAGATHI HOSPITAL EDUCATION TRUST

The ld. AR at the beginning of hearing submitted that the assessee has filed all the necessary documents desired by the ld. CIT(E) vide letter dated 07/02/2026, the acknowledgment of which is placed on page 26 of the paper book. However, the ld. CIT(E) without referring to the impugned documents vide order dated 10/03/2026 has dismissed both the appeals filed by the assessee for want of documents. Accordingly, the ld. AR prayed to set aside the issue to the file of the ld. CIT(E) for fresh adjudication in the light of the documents already submitted before the ld. CIT(E) and as per law. The ld. AR further assured to furnish any other documents to be desired by the ld. CIT(E).

On the other hand, the ld. DR raised no objection to restoring the impugned appeals to the file of the ld. CIT(E).

We have heard the rival contentions of both the parties and perused the materials available on record. Admittedly, the ld. CIT(E) has dismissed the appeals filed by the assessee for want of documents, whereas the facts show that the assessee has furnished requisite documents which is evident from page 26 of the paper book. Hence, in the interest of justice and fair play, we are inclined to set aside the issue to the ld. CIT(E) for fresh adjudication as per the provisions of law. The assessee is also at liberty to furnish other documents if so desired by the ld. CIT(E). The assessee is directed to cooperate with the proceedings and avoid unwarranted adjournments. In view of the above, the grounds of appeal of the assessee are hereby allowed for statistical purposes.

In the result, both the appeals of the assessee are allowed for statistical purposes.

Order pronounced in the open court on 5th October, 2026 Sd/- Sd/- SANDEEP SINGH KARHAIL WASEEM AHMED JUDICIAL MEMBER ACCOUNTANT MEMBER Bangalore Dated: 5th October, 2026 Vms

ITA 1418 & 1419/BANG/2026 PRAGATHI HOSPITAL EDUCATION TRUST

Copy to: PRAGATHI HOSPITAL EDUCATION TRUST, PRAGATHI HOSPITAL, MAIN ROAD, 1 BOLWAR,PUTTUR,DAKSHINA KANNADA- 574201, PUTTUR-574201, KARNATAKA THE COMMISSIONER OF INCOME TAX,(EXEMPTIONS), BANGALORE., 2 UNITY BUILDING ANNEX, MISSION ROAD,BANGALORE -560027, BENGALURU-560027, KARNATAKA 3 THE PCIT / CIT, 4 THE D.R., ITAT, BANGALORE BENCH 5 GUARD FILE By Order

ASSISTANT REGISTRAR / I.T.A.T., BANGALORE P G Digitally signed by P G RAJANI RAJANI Date: 2026.10.22 15:51:34 +05'30'

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