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IN THE INCOME TAX APPELLATE TRIBUNAL

AMRITSAR BENCH ‘DB’ : AMRITSAR

BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER

and

SHRI UDAYAN DAS GUPTA, JUDICIAL MEMBER

ITA No.205/ASR/2026

(Assessment Year: 2027-28)

ITA No.206/ASR/2026

(Assessment Year: 2027-28)

Village Health & Sanitation Improvement Trust, vs. CIT (Exemptions),

Bank Road, Civil Lines, Chandigarh.

Ludhiana - 141001 (Punjab).

(PAN : AAATV0586G)

(APPELLANT) (RESPONDENT)

ASSESSEE BY : Shri Pankaj Bhalla, CA

REVENUE BY : Mrs. Roshanta Kumari Meena, CIT DR

Date of Hearing : 23.07.2026

Date of Order : 23.07.2026

O R D E R

PER S. RIFAUR RAHMAN, AM:

1. The assessee has filed appeals against the order of the Learned

Commissioner of Income Tax (Exemptions), Chandigarh [“Ld. CIT(E)”,

for short] dated 22.12.2025 for the Assessment Year 2027-28 passed

under section 12A and 80G of the Income-tax Act, 1961 (for short ‘the

Act’).

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ITA Nos.205 & 206/ASR/2026

2. At the time of hearing, ld. AR of the assessee submitted that the ld. CIT

(E) erred in cancelling the assessee’s application filed in Form No.10AB

u/s 12A(1)(ac)(ii) of the Act by holding the same to be non-maintainable

which action is arbitrary, illegal and without authority of law and he

should not have cancelled the application without passing a reasoned

order. He further submitted that the assessee was required to file an

application u/s 10(46A) of the Act without appreciating that section

10(46A) is optional, conditional and applies only to specified bodies

notified by the Central Government and does not automatically bar

registration u/s 12A/12AB. Further, he submitted that ld. CIT (A) failed

to examine the assessee’s objects, activities and compliance with the

conditions prescribed u/s 11, 12 and 12AB of the Act and rejected the

application without any examination on merits. He, therefore, pleaded

that the matter may be restored to the ld. CIT (E) to decide afresh and

pass a reasoned order as per law after giving an opportunity of being

heard to the assessee.

3. On the other hand, ld. DR of the Revenue relied on the order of the ld.

CIT (E).

4. Considered the rival submissions and material placed on record. We

observed that the ld. CIT (E) summarily rejected the application as non-

maintainable. He has also not examined the assessee trust’s objects,

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ITA Nos.205 & 206/ASR/2026

activities and compliance with the conditions prescribed u/s 11, 12 and

12AB of the Act and rejected the application without any examination on

merits. In our considered view and in the interest of justice, assessee

should be given one more opportunity of being heard on merit.

Therefore, we restore the issue to the file of ld. CIT(E) and direct ld. CIT

(E) to give an opportunity of being heard to the assessee and decide the

issue on merit as per law. We also direct assessee to make proper

submissions and appear before the ld. CIT (E) on the date of hearing and

cooperate with the tax authorities. Accordingly, the appeals filed by the

assessee i.e. u/s 12A and 80G are allowed for statistical purposes.

5. In the result, both the appeals filed by the assessee are allowed for

statistical purposes.

Order pronounced in the open court on this 23^rd day of July, 2026

after the conclusion of the hearing.

sd/- sd/-

(UDAYAN DAS GUPTA) (S. RIFAUR RAHMAN)

JUDICIAL MEMBER ACCOUNTANT MEMBER

Dated: 23.07.2026

TS

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ITA Nos.205 & 206/ASR/2026

Copy forwarded to:

1. Appellant

2. Respondent

3. CIT

4. CIT(Appeals).

5. DR: ITAT

ASSISTANT REGISTRAR

ITAT, NEW DELHI