Facts
The assessees, being various trusts and societies, had their applications for registration under Section 80G of the Income Tax Act, 1961 rejected by the Commissioner of Income Tax (Exemption) due to non-submission of satisfactory evidence and relevant documents. The assessees appealed these rejections to the Income Tax Appellate Tribunal.
Held
The Tribunal found that the assessees had failed to produce necessary documents before the CIT(E) during the initial application stage. To ensure justice and fair play, the Tribunal decided to remand the matters back to the CIT(E) with a direction to re-examine the applications after allowing the assessees a reasonable opportunity to be heard and submit all required documents.
Key Issues
Whether rejection of application for registration under Section 80G for non-submission of documents is justified, and if remand is appropriate to allow submission of documents.
Sections Cited
80G
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, BENCH-RANCHI
Before: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahay
Assessment Year: 2025-26 Ramshobha Educational Welfare Trust………………..….….…………….…….…............................……….……Appellant Om Sai Apartment, Flat No.104, 104, Anantpur, Doranda Ranchi – 834002.. [PAN: AACTR0074R] vs. CIT (Exemption), Patna………..................................……........……...…..…..Respondent Assessment Year: 2024-25 Sarvoday Electronics And Welfare Trust………………..….….…………….…….…............................……….……Appellant C/o Saket Bihari, Booty, ITI, Sainik Colony, Booty More, Ranchi – 834001.. [PAN: AAMTS6970K] vs. CIT (Exemption), Patna………..................................……........……...…..…..Respondent Appearances by: Shri P S Paul, CA appeared on behalf of the appellant. Md. Shadab Ahmed, Sr. DR, appeared on behalf of the Respondent. Date of concluding the hearing : January 20, 2026 Date of pronouncing the order : January 21, 2026
I.T.A. Nos.450 to 452/Ran/2024 Ankur Rural And Tribunal Development Society ORDER
Per Sonjoy Sarma, Judicial Member:
The captioned appeals have filed by the different assessees against separate orders dated 25.09.2024, 25.09.2024 & 24.09.2024 passed by the CIT(Exemption), Patna rejecting application for registration u/s 80G of the Income Tax Act, 1961 (the ‘Act’). Since the issues involved in all these appeals are common, therefore, they were heard together and are being disposed of by this common order for the sake of convenience. First, we take up as a lead and the finding of this will apply to other connected appeal mutatis mutandis. facts of the case are that the assessee is a society and an application in Form 10AB was filed on 28.03.2024 by the assessee for grant of regular approval u/s 80G of the Act. The ld. CIT(E) rejected the application for grant of regular approval u/s 80G of the Act due to non-submission of satisfactory evidences by the assessee.
Dissatisfied with the above order, the assessee has filed the present appeals before this Tribunal. At the time of hearing, the ld. AR submitted that the assessee is now ready to submit the relevant documents for registration u/s 80G of the Act and prayed that the appeal may be remanded back to the file of the ld. CIT(E).
The ld. DR did not object to the above submission of the ld. AR.
We, after hearing both the parties and perusing the materials available on record, find that the assessee did not produce the relevant documents before the ld. CIT(E) and the ld. CIT(E) rejected the application for grant of regular approval u/s 80G of the Act due to non- to 452/Ran/2024 Ankur Rural And Tribunal Development Society submission of documents. We, therefore, on the request of the assessee and in the interest of justice and fair play, feel it necessary to remand the issue back to the file of the ld. CIT(E) with a direction to re-examine the issue afresh after giving reasonable opportunity of being heard to the assessee. We also direct the assessee to comply all notices and submit all the relevant documents/details during the remand proceedings for granting of application for registration u/s 80G of the Act. is therefore allowed for statistical purposes.
Since the issues involved in are identical in facts and circumstances, our findings and directions in shall apply mutatis mutandis to these appeals as well.
In terms of the above, the captioned appeals of the assessee are allowed for statistical purposes.
Kolkata, the 21st January, 2026.