IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, MUMBAI BEFORE HON’BLE JUSTICE (RETD.) C V BHADANG, PRESIDENT AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.1262 and 1263/MUM/2026 Assessment Year: -NA-

Amita Memorial Trust vs CIT (Exemption)

11 Himgiri 601, 6^th floor, Cumballa Hill Peddar Road MNTL TE Building, Mumbai-400026 Peddar Road Mumbai-400026 PAN: AAATA4232E Appellant Respondent Present for:

Appellant by : Shri K. Gopal & Ms Neha Paranjpe, Advocates Respondent by : Shri Rajesh Kumar Yadav, CIT DR Date of Hearing : 17.03.2026 Date of Pronouncement : 30.03.2026

O R D E R

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER These appeals filed by the assessee are arising out of the orders of ld. Commissioner of Income-tax (Exemptions), Mumbai [CIT(E)] vide order nos. ITBA/EXM/F/EXM45/2025-26/1085262370(1) and ITBA/EXM/F/EXM45/2025-26/1085262397(1) both, dated 28.01.2026 u/s 80G and 12AB(1)(b)(ii) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. Grounds taken by the assessee are as under:

A. ITA No.1262/Mum/2026 “1) The learned CIT (Exemptions) has erred in law and in facts in rejecting the application seeking registration under section 12AB of the Act without appreciating t