The Anglo Scottish Education Society vs the Commissioner of Income Tax (Exemptions) — Bombay HC (2026) — LawSathi Research

The Anglo Scottish Education Society vs the Commissioner of Income Tax (Exemptions) — Bombay HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Recall of both impugned orders dated 27th February, 2026; fresh consideration, strictly in accordance with applicable law and on merits, of the documents tendered with the earlier reply and the reply dated 11th November, 2025, with a reasoned order to be passed afresh; any renewal granted to relate back to 1st April, 2026; failing approval, liberty to pursue statutory remedies with all contentions kept open.

Issue for consideration

Whether the impugned orders dated 27th February, 2026 — passed on the premise that the Petitioner had not tendered the documents called for by the notices dated 4th November, 2025 — should stand recalled, given that the documents were in fact tendered on 11th November, 2025 and acknowledged on 12th November, 2025. +1 more

Court's answer

Both the orders dated 27th February, 2026 would lose their efficacy.

Ratio / Principle

The impugned orders would stand recalled.

Key takeaways

The documents tendered by the Petitioner, along with the earlier reply and the reply dated 11th November, 2025, would be considered strictly in accordance with the law applicable, on their merits, and a reasoned order would be passed afresh.ratio¶15
Any order passed by the Authorities relates back to the Petitioner's application for renewal of registration.ratio¶16
If, on the basis of the documents received by the Department on 12th November, 2025, the Department accepts the application for renewal and grants the renewal, the renewal shall relate back to 1st April, 2026, the renewal having been sought with effect from that date.

Detailed headnote1 paragraphs

Bombay High Court (Ordinary Original Civil Jurisdiction), Writ Petition No.1543 of 2026 — The Anglo Scottish Education Society v. The Commissioner of Income Tax (Exemptions), Mumbai & Anr. (decided 16.06.2026; Ravindra V. Ghuge, ACJ & Gautam A. Ankhad, JJ.). The Petition challenged orders dated 27.02.2026 concerning renewal of the Petitioner's registration, which proceeded on the premise that documents called for by notices dated 04.11.2025 had not been tendered, although the Petitioner's communication dated 11.11.2025 with the documents was received and acknowledged by Respondent No.1 under stamp dated 12.11.2025. The Department's advocate, under instructions, conveyed that the impugned orders would stand recalled and lose their efficacy, and that the tendered documents would be considered strictly in accordance with law, on merits, with a reasoned order to be passed afresh. The Court directed that any renewal granted shall relate back to 01.04.2026 (the renewal having been sought with effect from that date, the prior registration running till 31.03.2026); if renewal is not approved, the Petitioner may pursue statutory remedies with all contentions kept open. The Petition was disposed of with these directions.

IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION

WRIT PETITION NO.1543 OF 2026

The Anglo Scottish Education Society .. Petitioner Vs.

The Commissioner of Income Tax (Exemptions), Mumbai and Anr. .. Respondents

Mr. Raghav Gupta with Ms. Rashi Savla, Advocates, i/by Wadia Ghandy & Co., for the Petitioner.

Mr. Pritish Chatterjee, Advocate for the Respondents.

CORAM : RAVINDRA V. GHUGE, ACJ. & GAUTAM A. ANKHAD, J.

DATE : 16^TH JUNE, 2026.

P.C. :

We have heard the learned Advocates for the respective sides for quite some time. We have perused the impugned orders dated 27^th February, 2026. In light thereof, we have perused the notices dated 4^th November, 2025 issued to the Petitioner calling upon it to submit certain documents set out in the notices. In response thereto, the Petitioner has admittedly tendered a communication dated 11^th November, 2025 and enlisted the documents which were supposed to be filed by the Petitioner in response to the notices dated 4^th November, 2025. This communication along with the documents is received and

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acknowledged by Respondent No.1, Department, which is evident from the stamp dated 12^th November, 2025. The impugned order proceeds on the premise that the documents were not tendered by the Petitioner.

The learned Advocate representing the Department is under instructions to convey that the impugned orders would stand recalled and the documents which are tendered by the Petitioner along with earlier reply and the reply dated 11^th November, 2025, would be considered strictly in accordance with the law applicable and on their merits and a reasoned order would be passed, afresh. Needless to state, that both the orders dated 27^th February, 2026 would lose their efficacy.

It goes without saying that the Petitioner’s application was for renewal of registration which was to last till 31^st March, 2026. Any order passed by the Authorities relates back to the said application for renewal. If on the basis of the documents which are received by the Department on 12^th November, 2025, the Department accepts the application for renewal and grants the renewal, the same shall relate back to 1^st April, 2026 since the renewal sought was with effect from 1^st April, 2026. In the event, the Department does not approve the application for renewal, the Petitioner would be at liberty to avail of the remedy as is provided under the statute. All contentions would then be kept open.

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With the above directions, this Petition is disposed off .

[ GAUTAM A. ANKHAD, J. ]

[ ACTING CHIEF JUSTICE ]

Digitally signed by SNEHA ABHAY DIXIT Date: 908-WP-1543-2026.odt 2026.06.17 11:24:56 +0530

SNEHA ABHAY DIXIT

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