SACRED HEART EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTIONS WARD-2, CHENNAI

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ITA 2713/CHNY/2025Status: DisposedITAT Chennai26 November 2025AY 2022-234 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the denial of exemption under Section 11 by the CPC was based on the assessee not renewing its registration under Section 12A by filing the application under Section 12A(1)(ac)(i) before June 30, 2021. The assessee has since filed the renewal application before the CIT(Exemptions) along with a petition for condonation of delay. The Tribunal opined that the Addl. CIT(A) was not justified in dismissing the appeals without awaiting the decision of the CIT(Exemptions) on the Section 12A registration. Therefore, the matters were remitted back to the file of the Addl. CIT(A) for fresh adjudication after receipt of the decision from the CIT(Exemptions). The appeals were allowed for statistical purposes.

What were the facts?

The assessee, Sacred Heart Educational Trust, filed appeals for Assessment Years 2022-23 and 2023-24 against orders of the Learned Commissioner of Income Tax, Appeal, Addl./JCIT(A). The appeals challenge the denial of exemption under Section 11 of the Income-tax Act, 1961. The assessee, registered under Section 12A since 1992, failed to renew its registration by filing an application under Section 12A(1)(ac)(i) before the due date of June 30, 2021. Consequently, the CPC, Bengaluru, denied the Section 11 exemption in its intimation under Section 143(1). The assessee later filed a renewal application with a delay condonation petition before the CIT(Exemptions), Chennai, which was pending. The Addl. CIT(A) confirmed the denial of exemption.

What were the issues?

1. Whether the Tribunal had to decide if the assessee was entitled to exemption under Section 11 of the Income-tax Act, 1961, when its Section 12A registration had not been renewed by the stipulated deadline under Section 12A(1)(ac)(i). Assessee's contention: The assessee argued that since an application for renewal along with a delay condonation petition had been filed before the CIT(Exemptions), Chennai, the matter should be remitted back to the Addl. CIT(A) to await the decision of the CIT(Exemptions) on the registration. Revenue's contention: The Revenue relied on the orders of the lower authorities.

Which sections of the Income-tax Act were involved?

Section 11,Section 12A,Section 12A(1)(ac)(i),Section 143(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘D’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & SHRI JAGADISH

Pronounced: 26.11.2025

आदेश / O R D E R

PER JAGADISH, A.M : Aforesaid two appeals filed by the assessee for Assessment Years (AYs) 2022-23 & 2023-24 arises out of the orders of Learned Commissioner of Income Tax, Appeal, Addl./JCIT(A), Thiruvananthpuram [hereinafter “Addl. CIT(A)”] dated 11.07.2025 & 14.07.2025.

& 2714/Chny/2025 Sacred Heart Educational Trust :- 2 -:

2.

The common issue involved in both the appeals filed by the assessee is against the denial of exemption u/s. 11 of the Income-tax Act, 1961 (hereinafter “the Act”) by the Ld. Addl. CIT(A). The exemption was denied on the ground that the assessee-trust has not renewed the registration and therefore did not have a valid registration u/s. 12A of the Act,

3.

The assessee is a Trust registered u/s. 12A of the Act vide certificate dated 29.10.1992. The assessee did not renew the registration u/s. 12A of the Act by filing the renewal application u/s. 12A(1)(ac)(i) of the Act before 30.06.2021 . The assessee subsequently filed its return of income for A.Y 2022-2 on 18.07.2023 claiming exemption u/s. 11 of the Act. The CPC, Bengaluru, vide intimation u/s. 143(1) of the Act, did not allow the exemption u/s. 11 of the Act as the assessee was not registered u/s. 12A of the Act.

Thereafter, the assessee made an application before the Ld.

1.

1. CIT(Exemptions), Chennai, along with a petition for condonation of delay in filing the renewal application in Form 10A u/s. 12A(1)(ac)(i) of the Act, which is still pending. However, the Ld. Addl. CIT(A) confirmed the denial of exemption on the ground that the assessee did not have a valid registration u/s. 12A of the Act.

& 2714/Chny/2025 Sacred Heart Educational Trust :- 3 -:

4.

The Ld. Authorized Representative (A.R.) of the assessee submitted that exemption u/s. 11 of the Act has been denied solely because the assessee missed the timeline for filing the renewal application u/s. 12A(1)(ac)(i) of the Act. Since the assessee has now filed an application before the Ld. CIT(E), Chennai, along with petition for condonation of delay, it was prayed that the matter may be remitted back to the Ld. Addl. CIT(A) to await the decision of the Ld. CIT(E) on registration .

5.

On the other hand, the Ld. Departmental Representative (DR) relied on the orders of the lower authorities.

6.

We have heard the rival submissions and perused the materials available on record. The CPC has denied the exemption u/s. 11 of the Act as the assessee had not renewed its registration u/s. 12A of the Act by filing the application u/s.12A(1)(ac)(i) of the Act before 0.06.2021. The assessee has now filed the renewal application before the Ld. CIT(E) along with a petition for condonation of delay. We are of opinion that the Ld. Addl. CIT(A) was not justified in dismissing the appeals without awaiting for the decision of the Ld. CIT(E) on the registration u/s 12A. We therefore remit the matters back to the file of the Ld. Addl. CIT(A) for fresh adjudication after receipt of the decision & 2714/Chny/2025 Sacred Heart Educational Trust :- 4 -:

1.

of the Ld. CIT(E) . In view of the above, both the appeals filed by the assessee are allowed for statistical purposes.

7.

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

Order pronounced on 26th day of November, 2025 at Chennai.

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