AKHIL BHARAT SINDHI BRAHM KHATRI SAHAITA VIDYA TRUST,JAIPUR vs. CIT(E), JAIPUR, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “A” BENCH, JAIPUR BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI KULDIP SINGH, JUDICIAL MEMBER ITA Nos. 1262 & 1263/JPR/2026 (Assessment Year: NA) Akhil Bharat Sindhi Brahm Vs. CIT(E) Khatri Sahaita Vidya Trust Jaipur Kalani & Co LLP, Chartered Accountants, 5th Floor, Milestone Building, Gandhinagar Turn, Tonk Road, Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No: AAATA 6109Q Appellant .. Respondent Appellant by : Sh. P.C. Parwal, CA Respondent by : Sh. Anand Swaroop, CIT Date of Hearing 14.10.2026 Date of Pronouncement 15.10.2026 O R D E R Per Annapurna Gupta, AM:- Both the present appeals have been filed by the assessee against separate orders passed by the CIT Exemption Jaipur (hereinafter referred to as “Ld. CIT(E)”), both dated 14.03.2026 rejecting assessee’s

P a g e | 2 ITA Nos.1262 and 1263/JPR/2026 Akhil Bharat Sindhi Brahm Khatri Sahaita Vidya Trust application seeking approval under Section 80G of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) and registration under Section 12A of the Act respectively. 2. Approval u/s 80G of the Act has been denied on account of absence of registration u/s 12A of the Act. Since the issues involved in the appeals are interlinked, both the appeals were taken up for hearing together and are being disposed of by this common order. 3. Order of the ld. CIT(E) rejecting assessee’s application seeking registration u/s 12A of the Act reveals that the same was rejected for the reason that the assessee was not registered under the Rajasthan Public Trust Act 1959 (in short “RPT”) and on account of incomplete form 10AB. 4. The Ld. CIT(E) has passed an order after affording only two opportunities of hearing to the assessee . 5. During the course of the hearing, Ld. Counsel for the assessee has stated before us that an application for registration under the RPT Act has been filed before the Assistant Commissioner, Devasthan Vibhag, Jaipur, and the same is presently pending for consideration. The assessee has also placed on record before this Tribunal Form No. 6, in support of its submission regarding the registration proceedings pending before the competent authority. 6. Considering the above fact, clearly sufficient opportunity of hearing has not been given to the assessee by the Ld. CIT(E) while rejecting the application of the assessee. In the interest of justice

P a g e | 3 ITA Nos.1262 and 1263/JPR/2026 Akhil Bharat Sindhi Brahm Khatri Sahaita Vidya Trust therefore, we are of the view that the assesses application be reconsidered by the Ld. CIT(E) after giving due opportunity of hearing to the assessee. 7. Ld. DR fairly agreed to the same. 8. The application accordingly is restored back to the Ld. CIT( E) for consideration afresh after affording due opportunity of hearing to the assessee. 9. In effect, the appeal of the assessee in ITA No.1263/JPR/2026 stands allowed for statistical purposes. 10. Since the issue in the other appeal of the assessee in ITA No.1262/JPR/2026 relates to denial of grant of approval u/s 80G of the Act which was denied on account of the assessee being denied registration u/s 12AB of the Act, this issue is also restored back to the file of Ld. CIT(E) to be reconsidered along with assessee’s application u/s 12AB of the Act as directed above by us in assessee’s appeal in ITA No.1263/JPR/2026. 11. In effect, both of the appeals of the assessee stand allowed for statistical purposes. Order pronounced in the Open Court on 15.10.2026

Sd/- Sd/- (Kuldip Singh) (Annapurna Gupta) JUDICIAL MEMBER ACCOUNTANT MEMBER Dated 15.10.2026 Mittali, Sr. PS

P a g e | 4 ITA Nos.1262 and 1263/JPR/2026 Akhil Bharat Sindhi Brahm Khatri Sahaita Vidya Trust Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order, Asst. Registrar ITAT, Jaipur