Roman Catholic Church of St Stephen Vs CIT (Exemptions) (ITAT Mumbai)
Missed the First Notice for 12AB Renewal? Church Gets One More Chance, With a Clear Warning
Summary: The Roman Catholic Church of St Stephen applied to renew its registration under section 12AB. The Commissioner of Income Tax (Exemptions) asked for documents, but the institution did not supply them. Its application was rejected. Before the Mumbai Tribunal, the assessee acknowledged its failure to respond, attributing it to staff problems, and sought another opportunity.
The Tribunal restored the application for a fresh decision. It noted that the Commissioner had provided one opportunity, but had rejected the application without a further opportunity or a show-cause notice. The relief came with an express warning: the institution must now file the relevant documents without delay or default, and cannot expect leniency for another failure.
One Notice, No Documents, Then Rejection
The assessee, a charitable institution, filed its application for renewal under section 12AB on 30 September 2025. On 18 January 2026, the Commissioner issued a notice seeking the complete set of documents and details required under Rule 17A(2).
The institution did not comply with that notice. The Commissioner consequently rejected the application by order dated 4 March 2026.
