CONFRARIA DO SSMO SACRAMENTO E N SRA DE AMPARO DA IGREJA DE MANDUR,MANDUR vs. COMMISSIONER OF INCOME TAX (EXEMPTION), BENGALURU

ITA 248/PAN/2025Status: DisposedITAT Panaji06 March 2026Bench: HON’BLE SHRI PAVAN KUMAR GADALE (Judicial Member), SHRI G. D. PADMAHSHALI (Accountant Member)10 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(E) failed to confront the assessees with the specific negative observations or dissatisfactions before rejecting their applications, thus denying them a real and effective opportunity to be heard. Consequently, the impugned orders were set aside, and the cases were remanded to the CIT(E) for fresh adjudication with a direction to provide at least three effective opportunities to each assessee.

What were the facts?

Several assessees, primarily religious confraternities, applied for registration under Section 12AB of the Income Tax Act. The CIT(E) rejected their applications and cancelled provisional registrations due to the assessees' failure to submit required documents and provide satisfactory explanations regarding the genuineness of their activities and compliance with applicable laws, despite being given multiple opportunities.

What were the issues?

The key legal issues were whether the assessees were given a reasonable and effective opportunity to comply with documentation requirements and explain their activities, and whether the rejection of Section 12AB registration applications without confronting negative observations violated principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 12A(1)(ac),Section 2(15)

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Cases cited in this judgment(2)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, GOA BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI G. D. PADMAHSHALI, ACCOUNTANT MEMBER

DIN & Order No Sr Appeal No PAN Appellant Respondent Appealed Against

ITBA/EXM/F/EX Confraria De N Sra Do The Commissioner of ITA NO M45/2025- 1 AADTC0048H Rosario Da Capela De Income Tax, 237/PAN/2025 26/1077653258(1) Neura Exemption, Bangaluru dt. 24/06/2025

ITBA/EXM/F/EX The Commissioner of ITA NO Cofre Da capela De S AADTC0225A Income Tax, 238/PAN/2025 Sebastiao Neura 26/1077184423(1) Exemption, Bangaluru dt. 18/06/2025

Confraria Do SSMO ITBA/EXM/F/EX The Commissioner of ITA NO Sacramento E N Sra De AADTC0192Q Income Tax, 248/PAN/2025 Amparo Da Igreja De 26/1077647224(1) Exemption, Bangaluru Mandur dt. 24/06/2025

Confreria De N SRA Do ITBA/EXM/F/EX The Commissioner of ITA NO Bom Successo Da AADTC0176G Income Tax, 249/PAN/2025 Capela De Dongorim 26/1077647554(1) Exemption, Bangaluru Mandur dt. 24/06/2025

Confreria Do SSMO ITBA/EXM/F/EX The Commissioner of ITA NO Sacramento E Santos AABTC2267Q Income Tax, 347/PAN/2025 Reis Magos Da Igreja 26/1080241260(1) Exemption, Banga

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