आयकर अपील(cid:547)य अ(cid:876)धकरण,चÖडीगढ़ Ûयायपीठ, चÖडीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL DIVISION BENCH, ‘A’ CHANDIGARH BEFORE SHRI RAJPAL YADAV, VICE PRESIDENT AND SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No.225/CHD/2026 (cid:467)नधा(cid:91)रण वष(cid:91) / Assessment Year: 2026-27 Chandigarh Educational Society, The DCIT/ACIT, 1914G, Phase-10, Sector 55, Vs Central Circle-II, Rupnagar, SO Mohali. Chandigarh.

èथायी लेखा सं./PAN NO: AAAAC8124A अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent आयकर अपील सं./ ITA No.226/CHD/2026 (cid:467)नधा(cid:91)रण वष (cid:91) / Assessment Year: 2026-27 Chandigarh Educational Trust, The DCIT/ACIT, 2368, Phase-10, SAS Nagar, Vs Central Circle-II, Rupnagar, Mohali. Chandigarh.

èथायी लेखा सं./PAN NO: AABTC2038D अपीलाथ(cid:568)/Appellant (cid:292)×यथ(cid:568)/Respondent Assessee by : Shri Rohit Kapoor, Advocate and Shri Virsain Aggarwal, ITP Revenue by : Shri Manav Bansal, CIT, DR Date of Hearing : 26.02.2026 Date of Pronouncement : 21.04.2026 PHYSICAL HEARING O R D E R PER RAJPAL YADAV, VP The present two appeals are directed by two separate Charitable Institutions, namely “Chandigarh Educational Trust” (PAN-AABTC2038D) and “Chandigarh Educational Society” (PAN-AAAAC8124).

2. The grounds of appeal taken by each Institution read as under :

ITA 225/CHD/2026

1. The order rejecting renewal of registeration of the assessee society under 12A(1)(ac)(ii) of the Act, dated 26.12.2025, passed by the learned PCIT(Central) is bad in law, contrary to facts, and based on erroneous interpretation of statutory provisions and judicial precedents, and is therefore liable to be set aside.

2. That the jurisdiction assumed by the learned PCIT (Central)

Gurgaon in the proceedings under section 12A of the Act is bad in law on account of following:

2.1 That the PCIT (Central),Gurgaon has erred in exercising jurisdiction in a proceedings under section 12A of the Act in the case of the assessee society since, in view of Notification No. 52/2014 [F.No.187/38/2014(ITA.I)], the jurisdiction to take any action regarding registeration under section 12A of the Act in the instant case, vested exclusively with the Ld. CIT (Exemptions), Chandigarh.

3. That the learned PCIT (Central), Gurgaon exceeded the jurisdiction vested in law in a proceeding under section 12A of the Act on account of following:

3.1 That the learned PCIT (Central), erred in law by relying on records of A.Ys. 2014-15 to 2019-20 in the Show Cause Notice dated 17-12-2025 and final rejection order dated 26.12.2025, which is in contravention to Rule 17A of the Income-tax Rules, 1962, which permits examination of only three assessment years preceding the year of application. As the application before learned PCIT (Central) pertained to A.Y. 2026-27, only A.Ys. 2023-24 to 2025-26 could have been examined; hence, the show cause notice based on earlier years is legally untenable.

3.2 That the impugned order of the Ld. PCIT (Central), Gurgaon, founded solely on allegations relating to Assessment Years 2014-15 to 2019-20 (i.e., prior to 01.04.2022), is unsustainable in law, as the appellant trust had already been granted registration on 15.10.2021 for AYs 2022-23 to 2026-27, after the search dated 03.10.2019, and no adverse action could thereafter be taken on the basis of alleged past violations.

4. That the order of learned PCIT (Central), Gurgaon is violative of principles of natural justice since;

4.1 The learned PCIT (Central), Gurgaon, erred in cancelling the registration of the assessee society on various grounds which were never show caused to the assessee, hence, the order dated

26.12.2025 is bad in law.

5. That the order of the learned PCIT (Central), Gurgaon, is legally flawed and hit by the principle of judicial discipline since;

5.1 That the Ld. PCIT (Central), Gurgaon has erred in law and on facts in cancelling the registration of the appellant trust by completely ignoring the fact that the order passed by the Income-tax Settlement Commissi