MINDVALLEY CHARITABLE AND EDUCATION TRUST,CHENNAI vs. CIT (EXEMPTION), CHENNAI

ITA 4123/CHNY/2026Status: DisposedITAT Chennai05 October 2026AY 2025-267 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the primary issue was whether the assessee was afforded an effective opportunity to explain its case. The assessee's specific contention that the show-cause notice was sent to an incorrect email ID, leading to non-receipt and inability to furnish documents and explanations, was noted. The objections raised by the CIT(E) concerning delay in filing, supporting documents, and the nature of trust objects were material to the application's determination. The Tribunal emphasized that a meaningful opportunity of hearing requires the assessee to be put on notice of proposed adverse decisions and given a reasonable chance to present material. Since the assessee disputed effective service of the notice and expressed willingness to provide documents, and given that these matters require examination, the Tribunal found it appropriate to reconsider the matter at the CIT(E)'s level. The Tribunal explicitly stated it was not expressing any opinion on the merits of the registration claim. The impugned order was set aside, and the matter was restored to the CIT(E) for fresh adjudication after issuing a notice to the correct email ID, providing an effective opportunity to the assessee, and adjudicating afresh on merits.

What were the facts?

The assessee, MINDVALLEY CHARITABLE AND EDUCATION TRUST, had previously obtained registration under Section 12AB of the Income Tax Act, 1961, effective from AY 2022-23 to AY 2026-27. For continuation of this registration, the assessee filed Form No. 10AB on March 11, 2025. This application was allegedly rejected by the e-filing system due to a technical error, leading to a second filing on November 25, 2025. The Commissioner of Income Tax (Exemptions) [CIT(E)] issued a show-cause notice on June 17, 2026, raising issues regarding alleged delay in filing, the need for the earlier registration certificate, and certain religious objects of the trust. The assessee contended that the show-cause notice was not served on its correct email ID, thus preventing an effective opportunity to respond. Consequently, the CIT(E) passed an order dated June 25, 2026, rejecting the application.

What were the issues?

1. Whether the assessee was afforded an effective opportunity of being heard before the impugned order was passed by the ld. CIT(E)? (Question of law and fact, turning on principles of natural justice and procedural fairness). Assessee's contentions: - The impugned order was passed without granting an effective opportunity of being heard. - The initial Form No. 10AB application was filed within the prescribed time. - The second application was necessitated by a technical error in the Department's system. - The trust has a subsisting registration under Section 12AB, and relevant documents were previously examined. - Steps are being taken to amend the trust deed to address objections regarding religious objects. - The primary submission is that the show-cause notice was not communicated to the correct email ID, depriving the assessee of a chance to respond. - The matter should be restored to the CIT(E) for fresh adjudication with a proper opportunity. Revenue's contentions: - Not recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac),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), Chennai [hereinafter referred to as "the ld. CIT(E)"] dated 25.06.2026 in Form No. 10AD, whereby the applications filed by the assessee in Form No. 10AB u/s. 12A(1)(ac) of the Income Tax Act, 1961 ("the Act"), seeking registration u/s. 12AB of the Act, were rejected. Mindvalley Charit

The order continues below.

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