HARVEST MISSION FOR CHRIST IN INDIA,DR. DALALS COMPOUND KATOL ROAD NEAR MSEB BUILDING vs. ITO WARD-1, EXAMPTION,, NAGPUR

IN THE INCOME TAX APPELLATE TRIBUNAL
“NAGPUR” BENCH, NAGPUR
BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER &
SHRI KHETTRA MOHAN ROY, ACCOUNTANT MEMBER
(Physical hearing)

C.S.C., Education Society,
GTA and Co. LLP, 1st Floor,
Cathedral Building, Residency
Road, Sadar, Nagpur 440001. PAN : AAATC 6065 B

Vs
CIT(Exemption),
Income Tax Office, PMT Building,
Shankar Sheth Road, Pune -
411037

Appellant / Assessee

Respondent / Revenue
Asha Niketan Church Society,
GTA
&
CO.
LLP.,
Chartered
Accountant, 1stFloor Cathedral
Building, Residency Road, Sadar,
Nagpur, Maharashtra, 440001. PAN : AABTA3428M

Vs
ITO Ward -3, Exemption,
BSNL RTTC Building, Seminary
Hills, Nagpur, Maharashtra,
440006. Appellant / Assessee

Respondent / Revenue
Harvest Mission for Christ in India,
GTA
&
CO.
LLP.,
Chartered
Accountant, 1stFloor Cathedral
Building, Residency Road, Sadar,
Nagpur
MS
440001,
Nagpur,
Maharashtra, 440013. PAN : AAATH2760C

Vs
ITO WARD-1, Exemption,
BSNL, RTTC BUILDING,, NAGPUR,
Maharashtra, 440006
Appellant / Assessee

Respondent / Revenue

ITA No. 601 to 604/Nag/2024 (A.Y. 2024-25)
C. S. C. Education Society &Ors.

2
St Marys Church Society,
GTA & CO LLP, Chartered
Accountant, 1st Floor, Cathedral
Building, Residency Road, Sadar,
Nagpur. MS - 440001,
Chandrapur, Maharashtra,
441221

PAN : AADTS0467L

Vs
ITO WARD-3, Exemption,
BSNL RTTC, BUILDING, NAGPUR,
Maharashtra, 440006
Appellant / Assessee

Respondent / Revenue

Assessee by Shri G.Kurin, Advocate
Revenue by Shri Pankaj Kumar, CIT–DR
Date of hearing
19.02.2026
Date of pronouncement
12.03.2026

Order under section 254(1) of Income Tax Act

PER PAWAN SINGH, JUDICIAL MEMBER: 1. These four appeals by different society-trust (assessee) are directed against the separate orders of ld. Commissioner of Income Tax (Exemption) [for short “CIT(E)”] rejecting application for registration of Trust/ society under section 12AB. Facts in all the appeals are similar, all the appellants/ assessees have raised certain similar grounds of appeal, therefore, with the consent of both the parties, both the appeals were heard together. For appreciation of facts, the appeal in ITA No 601/Nag/2024 is treated as lead case. 2. Rival submissions of both the parties have been heard and record perused. The ld. Authorised Representative (AR) of the assessee submits that assessee is a charitable Trust /Institution, filed application for registration of Trust under section 12AA/12AB on 27.03.2024. At the time of filing online application, the assessee furnished all the required evidence and information.

ITA No. 601 to 604/Nag/2024 (A.Y. 2024-25)
C. S. C. Education Society &Ors.

In response to show cause notice by ld. CIT(E) the assessee again furnished required details. The ld. A.R. submits that once the assessee furnished evidence about the object and activities, the assessee is eligible for registration under section 12AB. The ld. AR of the assessee prayed for allowing all the appeals with direction to ld. CIT(E) for granting registration forthwith. In alternative and without prejudice submission, the ld. AR of the assessee submits that all the appeals may be restored to the file of ld. CIT(E) for passing the order afresh, after considering the evidence on record.
3. On the other hand, ld. CIT–DR for revenue submits that assessee has not responded in response to notice issued by CIT(E). the ld. CIT(E) in his finding has clearly recorded that the assessee failed to furnish required evidence, the assessee in its reply dated 22.09.2024, did not furnish point wise (issue wise) reply response to show cause as it has been clearly recorded in para- 6. Thus, from the conduct of assessee it was clear that they are not interested in furnishing the required evidence to substantiate object, activities and compliance on any other law, entitling them for registration under section 12AB, therefore, all the assessees are not eligible for any relief from this Tribunal. All the appeals may be dismissed.
4. We have considered the rival submissions of both the parties and have gone through the orders of lower authorities carefully. On perusal of impugned order passed by ld. CIT(E), we find that at the time of the filing application online the assessee furnished certain details and evidence. Further, in response to the show cause notice dated 15.09.2024, the assesse also filed its response with certain other details vide reply dated 20.09.2024. The ld.

ITA No. 601 to 604/Nag/2024 (A.Y. 2024-25)
C. S. C. Education Society &Ors.

CIT(E) was of the view that assessee has not furnished point-wise reply to his notice and merely furnished list of donations made by it. However, it is not clarified whether such institutions have similar objectives as of the assessee.
He was further of the view that donations given to other institutions is as per objects of the assessee. Resultantly, the application of assessee for registration under section 12AA/12AB was rejected for the want of compliance. Considering the facts and circumstances of the case, in our view the assessee deserves one more opportunity to explain its objects and activities for seeking registration under section 12AB, therefore matter is restored back to the file of CIT(E) to re–consider the application afresh.
Needless to direct that before passing the order, the ld. CIT(E) shall allow fair and reasonable opportunity to the assessee. The assessee is also directed to be more vigilant in future towards making timely compliance and providing required details to the office of CIT(E). In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes.
5. In the result, ITA No. 601/Nag/2024 is allowed for statistical purposes.
ITA Nos. 602 to 604/Nag/2024
6. We find that the facts in these appeals are similar; the assessee(s) in their respective appeals have raised similar grounds of appeal. Thus, considering the facts, we have restored similar appeal in ITA No. 601/Nag/2024 to the file of ld CIT(E), hence, these appeals are restored back with similar directions.

ITA No. 601 to 604/Nag/2024 (A.Y. 2024-25)
C. S. C. Education Society &Ors.

Mumbai , Dated: 12/03/2026 PAWAN SINGH
JUDICIAL MEMBER

Self by author

Copy of the order forwarded to:
(1)
The Assessee;
(2)
The Revenue;
(3)
The PCIT / CIT (Judicial);
(4)
The DR, ITAT, Nagpur; and (5)
Guard file.
By Order