UTTAR PRADESH MITRA MANDAL TRUST,DELHI vs. CIT (EXEMPTION), DELHI

ITA 964/DEL/2025Status: DisposedITAT Delhi28 January 2026Bench: Sh. Satbeer Singh Godara, Judicial Member & Sh. Manish Agarwal (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that there was no adjudication on merits regarding the assessee's objects and activities. Therefore, the matter was restored back to the CIT(E). The CIT(E) was directed to afford three effective opportunities to the assessee to file complete details, which would then be considered as per law.

What were the facts?

The assessee's appeal was filed against the CIT(Exemption)'s order dated 20.12.2024, which refused section 12AA registration. The CIT(Exemption) cited that the assessee failed to provide all requisite information regarding the genuineness of its activities. The assessee's counsel contended that all evidence was duly filed and considered in the lower proceedings.

What were the issues?

Whether the CIT(Exemption) rightly refused section 12AA registration without adjudicating on the merits of the assessee's activities and objects?

Which sections of the Income-tax Act were involved?

Section 12AB(1)(b)(ii),Section 12AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘E’, NEW DELHI

For Appellant: Adv. &
For Respondent: Ms. Amish S. Gupt, CIT-DR
Hearing: 28.01.2026Pronounced: 28.01.2026

Per Satbeer Singh Godara, Judicial Member:

This assessee’s appeal arises against the CIT(Exemption), Delhi’s DIN & order No. ITBA/EXM/F/EXM45/2024– 25/1071425041(1) dated 20.12.2024, in proceedings u/s 12AB(1)(b)(ii) of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

It emerges during the course of hearing that the learned CIT(Exemption) has refused section 12AA registration to the assessee after observing in para 5 of the impugned order that it had failed to file all the requisite information sought qua

2 Uttar Pradesh Mitra Mandal Trust genuineness of the various activities carried out in the lower proceedings.

4.

Learned counsel on the o

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 12AB(1)(b)(ii)

All 150 judgments and leading authorities on Section 12AB(1)(b)(ii) →

Recent GST High Court judgments

Search GST case law →