SATYALOK KRIYA YOGA,JAMSHEDPUR vs. EXEMPTION WARD, JSR, JAMSHEDPUR

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ITA 300/RAN/2024Status: DisposedITAT Ranchi18 September 2025Bench: SHRI SONJOY SARMA, JUDICIAL MEMBER SHRI RATNESH NANDAN SAHAY (Accountant Member)4 pages

AI SummaryRemanded

Facts

The assessee applied for regular registration under section 12A(1)(ac)(iii) and various exemptions (u/s 11, 10(23AA), 10(23C), 80G), all of which were rejected by the CIT(E). The rejection stemmed from the assessee's partial compliance with notices and failure to provide supporting documents to substantiate its activities as charitable or religious. The assessee contended that it did not receive notice regarding specific objections raised by the CIT(E) concerning the trust's object clause.

Held

The Tribunal observed that the assessee could not present the facts as required by the CIT(E). In the interest of justice and fair play, the appeal was remanded back to the CIT(E) for fresh examination. The CIT(E) was directed to provide the assessee with a reasonable opportunity of being heard, and the assessee was instructed to comply with all future notices.

Key Issues

Whether the rejection of the application for regular registration under Section 12A due to non-submission of documents was justified, given the assessee's claim of not receiving notice for specific objections, raising a question of natural justice.

Sections Cited

Section 12A(1)(ac)(iii), Section 12AB(1)(b), Section 11, Section 10(23AA), Section 10(23C), Section 80G, Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “RANCHI BENCH”, RANCHI

301, 303, 304, 305 & 306/RAN/2024 Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation Appearances by: Assessee represented by : R.R. Mittal, AR Department represented by : Rinku Singh, CIT-DR Date of concluding the hearing : 10.09.2025 Date of pronouncing the order : 18.09.2025 O R D E R PER SONJOY SARMA, JUDICIAL MEMBER Captioned appeals are filed by the different assessee against the separate orders passed by the Ld. Commissioner of Income Tax (Exemptions) [hereafter “the Ld. CIT(E)], where the application of the assessee filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A of the Act was rejected and also filed application for exemption u/s 11 or u/s 10(23AA) or u/s 10(23C) of the Act or getting benefit u/s 80G of the Act which was rejected. Since, the issues in all the appeals are common except the figures and parties name, therefore, all the appeals are heard together and pass this consolidated order in the appeals. First, we take up the ITA No. 301/RAN/2024.

Brief facts of the case are that the assessee filed an application in Form No. 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A read with section 12AB(1)(b) of the Act. In the course of proceedings taken u/s 12AB of the Act, the Ld. CIT(E) examine the objects of the applicant and the genuineness of the activities and the compliance of such requirement of any other law for the time being in force by the trust or institution as are material for the purpose of achieving its object. In this connection, the Ld. CIT(E) asked certain details from the assessee but the assessee partially complied to the notices issued by the Ld. CIT(E) and fail to furnish the supported documents in order to prove the genuineness of its activities as claimed to have been carried out in accordance with the object of the trust wholly for charitable 301, 303, 304, 305 & 306/RAN/2024 Satyalok Kriya Yoga, Vishwa Nirmala Dharma, G.D. Rungta Foundation or religious purposes within the meaning of section 11 read with section 2(15) of the Act. Therefore, the application filed in Form 10AB for grant of regular registration under sub clause (iii) of clause (ac) of sub-section (1) of section 12A was rejected.

Aggrieved by the above order, the assessee is in appeal before this Tribunal raising various grounds. However, primary contention of the assessee is that while passing the impugned order, the assessee has submitted all supported documents before the Ld. CIT(E) but relating to the objections raised by the Ld. CIT(E) while passing the order relating to the object clause of the trust to prove the fact that it is a charitable or religious purposes within the meaning of section 11 read with section 2(15) of the Act, the assessee did not get any notice therefore, the assessee could not comply to the queries made by the Ld. CIT(E). Accordingly, the application for granting regular registration was rejected. He therefore, prayed that considering the facts of the case another chance may be given to the assessee so as to the assessee may submit supported documents in order to substantiate its claim.