People Education Trust Vs CIT (Karnataka High Court)
12A Registration Continuation Order Quashed for Breach of Natural Justice; Non-Supply of Investigation Report Held Fatal
The Karnataka High Court, in People Education Trust vs. Commissioner of Income Tax (Exemptions) (W.P. No. 13081 of 2025, order dated 01-Dec-2025), set aside the order dated 31-03-2025 passed u/s 12AB / Form 10AB, whereby continuation of registration u/s 12A was denied, holding that the proceedings suffered from a clear violation of principles of natural justice.
The Court noted that while processing the Trust’s application for continuation of registration, the matter was referred to the jurisdictional Assessing Officer for verification, and an investigation report was submitted to the CIT(E). However, the impugned order was passed solely relying on the said investigation report and other materials, without furnishing the report to the Trust and without granting sufficient or reasonable opportunity to rebut the findings.
Holding that non-supply of the investigation report and denial of effective opportunity strikes at the root of fair adjudication, the High Court ruled that the impugned order was unsustainable in law. On this short ground alone, the Court quashed the order and remanded the matter to the CIT(E) for fresh consideration in accordance with law, with directions to provide the Trust full disclosure of material relied upon, grant adequate hearing, and thereafter pass a reasoned order.
The Trust was directed to appear on the specified date, liberty was reserved to file additional replies and documents, and it was clarified that failure to appear would result in automatic recall of the relief granted.
FULL TEXT OF THE JUDGMENT/ORDER OF KARNATAKA HIGH COURT
