TaxTMI 
TaxTMI 
2026 (9) TMI 976
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....ders, are intrinsically connected. ITA No. 1059/Jodh/2026 arises from the order dated 27.02.2026 passed by the learned Commissioner of Income-tax (Exemption), Jaipur ["Ld. CIT(E)"] pursuant to the directions of this Tribunal in an earlier round, whereas ITA No. 969/Jodh/2025 arises from the order dated 17.09.2025 passed by the learned Addl./JCIT(A)-1, Chennai, in relation to the adjustment under section 143(1) for A.Y. 2018-19. Since the outcome of the latter appeal is consequential upon the issue of registration involved in the former, both the appeals were heard together and are being disposed of by this consolidated order. 2. We first take up ITA No. 1059/Jodh/2026. The relevant facts are that the assessee had originally filed an appl....
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....ffect to the Tribunal's order, the Ld. CIT(E) could not have altered the character of the original application and treated it as one filed under section 12AB. 5. We have considered the submissions and perused the material placed before us. The factual position is quite manifest from the record. The assessee's application was filed on 25.09.2020 in Form No. 10A seeking registration under section 12AA. It was this application which was rejected, which thereafter became the subject matter of appeal before the Tribunal and which was ultimately restored to the Ld. CIT(E) for fresh adjudication. Thus, the proceedings before the Ld. CIT(E) pursuant to the Tribunal's order dated 03.11.2022 were nothing but a continuation of the original proceedi....
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.... assessee had filed its return of income for the relevant assessment year on 31.08.2018 declaring total income of Rs.5,06,614. The return was processed under section 143(1) on 16.12.2019 and the benefit claimed under sections 11 and 12 was denied. The assessee carried the matter in appeal. The learned Addl./JCIT(A)-1, Chennai, vide impugned order dated 17.09.2025, dismissed the appeal essentially on the ground that, during A.Y. 2018-19, the assessee did not possess registration under section 12AA and, therefore, the CPC was justified in denying exemption under sections 11 and 12. 9. Before us, the Ld. Counsel submitted that the very basis on which the learned first appellate authority dismissed the appeal now stands materially altered. H....