Doddaballapura Planning Authority Vs CIT (Exemptions) (ITAT Bangalore)
The assessee, a statutory body established under the Bangalore Metropolitan Region Development Authority Act, 1985, appealed against the order dated 24/11/2025 passed by the Commissioner of Income Tax (Exemptions), Bangalore, rejecting its application for renewal of registration under Section 12AB of the Income Tax Act, 1961. The assessee performs statutory functions relating to planned development and coordination among civic bodies and operates under the control of the State Government.
The assessee’s earlier application for registration under Section 12A was rejected on 31/03/2021 because relevant details were not filed to establish the genuineness of its objects and activities. Subsequently, it applied for regular registration under Section 12A(1)(ac)(i), which was granted through Form 10AC dated 15/11/2021 for assessment years 2022-23 to 2026-27.
As that registration was due for renewal, the assessee filed Form 10AB under Section 12A(1)(ac)(ii) on 27/09/2025. The CIT(E), however, rejected the application on the ground that the earlier registration under Section 12A(1)(ac)(i) had itself been wrongly granted because the assessee did not hold a subsisting registration under Section 12A or 12AA immediately before migration to the new regime.
Assessee’s Submissions and Revenue’s Stand
The assessee submitted that the CIT(E) had not considered its submissions and documents and had exceeded jurisdiction by treating the earlier registration as invalid without following the statutory procedure for cancellation under Section 12AB(4). According to the assessee, the registration granted on 15/11/2021 remained subsisting because it had never been revoked under the procedure prescribed by law.
