Roman Catholic Church of St Stephen vs. Commissioner of Income Tax (Exemptions)

Parties Involved

Facts Summary

The assessee, a charitable institution, filed an application dated 30.09.2025 for renewal of registration under section 12AB of the Income Tax Act, 1961. The Commissioner of Income Tax (Exemptions) issued a notice dated 18.01.2026 seeking complete set of documents/details as required under Rule 17A(2). However, the assessee failed to comply with the notice, leading to the rejection of the application on 04.03.2026. The assessee appealed against this order, arguing that the Commissioner did not provide proper opportunity to furnish the required details and that the rejection was due to staff problems. The assessee cited several orders from other benches of the Tribunal for similar facts and requested the matter be sent back to the Commissioner for reconsideration.…

Legal Issues

• 1. Whether the Ld. CIT (Exemptions) erred in passing order u/s. 12AA denying registration to the appellant u/s. 12AB of the Income Tax Act, without specifying the conditions that were not complied with, by the Appellant/assessee.
• 2. Whether the Ld. CIT (Exemptions) was not justified in denying registration without putting the assessee to notice, as to what details were required to be filed by the Assessee with the Ld. CIT(E).
• 3. Whether the Ld. CIT (Exemptions) misdirected himself in not specifying the details not filed by the assessee.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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