DAGA EDUCATIONAAL AND CHARITABLE TRUST,TIRUVANNAMALAI vs. COMMISSIONER OF INCOME TAX (EXEMPTION), CHENNAI

ITA 3065/CHNY/2026Status: DisposedITAT Chennai05 October 2026AY 2026-275 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the assessee's contention regarding the communications being sent to an incorrect email ID, leading to a lack of effective opportunity, had force. The Tribunal emphasized that the requirement of granting a reasonable and effective opportunity of hearing cannot be treated as a mere procedural formality and that the assessee must have a real and meaningful opportunity to present its case. Since the rejection of the applications was substantially influenced by the assessee's failure to furnish documents, and the assessee claimed this non-compliance was not deliberate but due to incorrect email communication, the Tribunal found merit in reconsidering the matter. The Tribunal set aside the impugned order and restored the applications to the file of the CIT(E) for fresh adjudication, directing the CIT(E) to issue proper notice at the correct email address, afford an effective opportunity, and decide afresh. The assessee was directed to update its email ID and cooperate. The Tribunal explicitly stated it was not expressing any opinion on the merits of the applications.

What were the facts?

The assessee, Daga Educational and Charitable Trust, filed an appeal against the order dated 26.05.2026 passed by the Commissioner of Income Tax (Exemptions) [CIT(E)]. The CIT(E) had rejected the assessee's applications filed in Form No. 10AB seeking registration under Section 12AB of the Income Tax Act, 1961, for the assessment year 2026-27. The assessee contended that deficiency letters and show-cause notices issued by the CIT(E) were sent to an incorrect email ID, due to which the assessee was unaware of the deficiencies and could not furnish the required documents within the stipulated time. The assessee expressed readiness to provide all necessary documents and explanations. The revenue relied on the impugned order.

What were the issues?

1. Whether the rejection of the assessee's applications for registration under Section 12AB of the Income Tax Act, 1961, was valid, considering the assessee's claim that it did not receive the deficiency letter and show-cause notice due to communication sent to an incorrect email ID? Assessee's contention: The assessee argued that the rejection was contrary to the principles of natural justice as it was deprived of an effective opportunity to respond to the deficiencies pointed out by the CIT(E) because the relevant communications were sent to an incorrect email ID. The assessee was willing to furnish all required documents, including the trust deed, financial statements, and details of charitable activities. Revenue's contention: The revenue relied on the impugned order and argued for the dismissal of the appeal.

Which sections of the Income-tax Act were involved?

Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: GAGAN GOYAL & SHRI MANU KUMAR GIRI

Hearing: 22.09.2026

PER MANU KUMAR GIRI, JM:

This appeal filed by the assessee is directed against the order passed by the ld. Commissioner of Income Tax (Exemptions) [hereinafter referred to as "the ld. CIT(E)"] dated 26.05.2026, whereby the applications filed by the assessee in Form No. 10AB u/s. 12AB(1)(b)(ii) of the Income Tax Act, 1961 ("the Act"), seeking registration u/s. 12AB of the Act, came to be rejected. :

The order continues below.

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