Anasuya Mudde Gowda Charitable Trust Vs CIT (Exemptions) (ITAT Bangalore)
Summary: The assessee, Anasuya Mudde Gowda Charitable Trust, constituted by deed dated 28.04.2003 with objects including relief to the poor, medical relief and education to the public without discrimination based on caste, community or religion, had obtained provisional registration under Section 12A/12AB and provisional approval under Section 80G for AYs 2022-23 to 2026-27. It filed separate applications in Form 10AB on 16.06.2025 seeking regular registration under Section 12AB and approval under Section 80G. The CIT(Exemptions), Bengaluru rejected both applications on 19.12.2025 on the ground that the assessee had not responded to notices, appeared for proceedings or furnished the necessary documents/details. Before the Tribunal, however, the assessee produced the notices, replies and acknowledgements showing that, pursuant to the CIT(E)’s directions, it had appeared before the ITO (Exemptions), Ward-1, Mysuru, and furnished the required details through Tappal on 29.09.2025 and 08.10.2025. On examining the paper book and material on record, the Bangalore ITAT found that the assessee had complied with the directions and that the CIT(E)’s findings that the assessee had not responded to the notices were incorrect, baseless and against the actual facts. In the interest of justice, equity and fair play, the Tribunal therefore remitted both the registration and approval issues to the CIT(E) for fresh consideration in accordance with law after taking into account the responses filed before the ITO(E), with a reasonable opportunity of being heard to the assessee. The assessee was also directed to furnish any other documents, records, information, accounts or reports that might be required. Both appeals were partly allowed for statistical purposes; the Tribunal did not itself grant the Section 12AB registration or Section 80G approval.
