JEEVAN SHIKSHAN SANSTHA,PUNE vs. THE CIT EXEMPTION, PUNE

IN THE INCOME TAX APPELLATE TRIBUNAL, PUNE BENCH “A” BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER I.T.A.No.1299/PUN/2026 Jeevan Shikshan Sanstha CIT (Exemption) PO- Urun, Islampur, 322, 3rd floor, ITO, PMT Walwa Building, Singli-415409, Vs. Swargate, Maharashtra. PAN: AAETJ1841N Pune-411037, Maharashtra. (Appellant) (Respondent) For Assessee : None For Revenue : Shri Mithun Shete, CIT DR Date of Hearing : 15.10.2026 Date of Pronouncement : 16.10.2026 ORDER PER PAVAN KUMAR GADALE, JUDICIAL MEMBER:- The assessee has filed the appeal against the order of the CIT (Exemption) Pune passed u/sec 12A of the Income Tax Act, 1961 The assessee has raised the grounds of appeal challenging the order of the CIT (Exemp) rejecting the application filed for registration u/s.12AB of the Income Tax Act. 2. At the time of hearing, it was brought to the knowledge of the bench, that there is a delay of 23 days in filing the appeal before the Hon'ble Tribunal and the assessee has filed the application for condonation of delay. On consideration of facts and circumstances mentioned in the application, there is a reasonable cause explained and the Ld.DR has no specific

ITA.No.1299/PUN/2026 Jeevan Shikshan Sanstha objection. Accordingly, the delay is condoned and the appeal is admitted. 3. The brief facts of the case are that, the assessee was granted provisional registration u/s.12A(1)(ac)(vi)(A) of the Act in form no.10AC on 31.03.2025. Subsequently, as per the amended provisions of section 12AB of the Act, The assessee for the purpose of permanent registration has uploaded separate e-applications in Form.No.10AB on 03.06.2025. Whereas the office of the CIT (Exemption) has issued notice for the clarifications and information and the assessee has duly complied with the details. Whereas the CIT (Exemption) observed that the since the activities were commenced on 30.05.1990 before obtaining the provisional registration in Form>no.10AC on 31.03.2025, the assessee was required to file application u/sec12A(1)(ac)(vi)(B) of the Act instead of u/sec12A(1)(ac)(ii)(A) of the Act and has rejected the applications vide order dated 13.12.2025. Aggrieved by the CIT (Exemption) orders, the assessee has filed the appeal before Hon’ble Tribunal. None appeared on behalf of the assessee. 4. We heard the Ld.DR submissions and perused the material on record. The assessee has filed application before the CIT (Exemption) for registration u/sec12A of the Act. The assessee in the course of hearing has filed details in compliance to the notices issued by the CIT (Exemption). Whereas the assessee by mistake mentioned wrong code in the application i.e u/sec12A(1)(ac)(vi)(A) of the Act instead of u/sec12A(1)(ac)(ii)(B) of the Act and the CIT(E) has rejected the application vide order dated 13.12.2025. The assessee mentioned in the grounds of appeal that the nature of activities are charitable and the CIT (Exemption) has rejected

ITA.No.1299/PUN/2026 Jeevan Shikshan Sanstha the application in mechanical manner without examining the genuineness of activities and substantive merits. We considering the facts, circumstances and principle of natural justice shall provide with one more opportunity of hearing to the assessee to substantiate the case along with evidences and information. Accordingly, we set aside the order of the CIT (Exemption) to de novo consider the applications as per the law and we allow the ground of appeal of the assessee for statistical purposes. 5. In the result, the appeal filed by the assessee is allowed for statistical purposes.

Order pronounced in the open Court on 16th October, 2026. Sd/- Sd/- DIPAK P. RIPOTE PAVAN KUMAR GADALE (ACCOUNTANT MENBER) (JUDICIAL MEMBER) Pune; दिन ांक / Dated: 16th October, 2026 Abhishek Mohan आिेशकीप्रतितितिअग्रेतिि / Copy of the Order forwarded to : अिीि र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent. 2. 3. The Pr. CIT concerned. 4. तिभ गीय प्रतितनति, आयकर अिीिीय अतिकरण, “A” बेंच, पुणे/ DR, ITAT, “A” Bench, Pune. ग र्डफ़ इि / Guard File. 5. //true copy//

आिेश नुस र / BY ORDER, Digitally signed by Sunil Kumar Sunil Kumar More More Date: 2026.10.25 10:46:50 +05'30' Assistant Registrar, आयकरअिीिीयअतिकरण,/ ITAT, Pune.