IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER ITA No.4309/Del/2025 Electric Lamp and Component CIT (Exemption)

Manufacturers Association of Delhi.

India, Vs. (Civic Centre Minto Road, C/o Kapil Goel, Adv. Delhi-110002).

G-8/5 Sector-11, Opposite SFS Apartment, Rohini, Delhi-110085.

PAN-AAATE0234A (Appellant) (Respondent)

Assessee by Dr. Kapil Goel, Adv.

Department by Shri Jitender Singh, CIT-DR Date of Hearing 24/11/2025 Date of Pronouncement 21/01/2026

O R D E R

PER MANISH AGARWAL, AM:

The present appeal is filed by the assessee against the order of Learned Commissioner of Income Tax (Exemptions) dated 30.06.2025 passed u/s 12AB(1)(b) of the Income Tax Act, 1961 (‘the Act’ in short) rejecting the registration applied by the assessee u/s 12A of the Act for the period from Assessment Years 2021-22 to 2025-26.

2. Brief facts of the case are that the appellant society was incorporated on 29.06.1970 and registered u/s 12A of the Act in terms of registration certificate issued on 30.09.1986. Thereafter, assessment for Assessment Years 2013-14 and

2015-16 were completed on 29.03.2016 and 11.12.2017 respectively, wherein assessee was allowed exemption u/s 12A of the Act. The assessee was granted registration u/s 12AB of the Act for Assessment Year 2021-12 to 2023-24 vide order dated 27.05.2021, thereafter, assessee applied for permanent approval u/s 12A which was rejected by Ld. CIT(E) vide order dated 30.06.2025 and further cancel the provisional registration granted from Assessment Year onwards.

3. Aggrieved by the said order, assessee is in appeal before the Tribunal by taking following grounds of appeal:

A) That Ld. CIT Exemption vide impugned order passed us 12AB(1)(b) of the Act (1961 erred in not Act) renewing/granting the registration of applicant assessee u/s 12AB(1) of 1961 Act and erred in rejecting the appellant's application and erred in cancelling the registration for the period from A.Y. 2021-22 to AY 2025-

26 based on untenable/arbitrary/irrational reasoning/grounds;

B) That Ld. CIT Exemption vide impugned order passed us 12AB(1)(b) of the Act (1961 Act) erred in not renewing/granting the registration of applicant assessee w/s12AB(1) of 1961 Act without appreciating that assessee’s objects/activities have been throughout treated as charitable under 1961 Act right from inception and is duly assessed u/s 143(3) as such, thus acting against principle of consistency.

C) That Ld. CIT Exemption vide impugned order passed us 12AB(1)(b) of the Act Act) in (1961 erred not renewing/granting the registration of applicant assessee w/s12AB(1) of 1961 Act without appreciating that assessee’s stated "objects"

duly qualify charitable in nature u/s 2(15) of 1961 Act as ;

D) That Ld. CIT Exemption vide impugned order passed us 12AB(1)(b) of the Act (1961 erred in not Act) renewing/granting the registration of applicant assessee u/s12AB(1) of 1961 Act transgressing/going beyond the well settled scope of permissible examination u/s 12AB of 1961 Act;

E) That Ld. CIT Exemption vide impugned order passed us 12AB(1)(b) of the Act (1961 Act) erred in not renewing/granting the registration of applicant assessee u/s12AB(1) of 1961 Act without appreciating that similar assessee’s have been treated as charitable organization u/s 2(15)/sec 11 of 1961 Act in series of binding judicial precedents;”

4. Since all the grounds of appeal are with respect to rejection of application for registration u/s 12A and withdrawal of provisional registration granted, therefore, all the grounds of the appeal of the assessee are taken together for consideration.

5. Before us, the Ld. AR for the assessee submits that main object of the assessee is of charitable in nature which has been accepted by the Department in the orders passed u/s 143(3) of the Act for preceding assessment years and no doubts were raised. Ld. CIT(E) while withdrawing exemption has not appreciated this fa