NALANDA FOUNDATION MARUDHARA,JAIPUR vs. COMMISSIONER OF INCOME TAX(EXEMPTION),JAIPUR, JAIPUR

ITA 762/JPR/2026Status: DisposedITAT Jaipur16 September 2026AY 2025-266 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(E)'s order under section 12AB was based on a flawed premise regarding the cancellation of provisional registration and that the assessee was not given a proper opportunity to address deficiencies. Consequently, both orders were set aside and the applications were restored for fresh consideration.

What were the facts?

The assessee, Nalanda Foundation, applied for registration under section 12AB and approval under section 80G. The CIT(E) rejected both applications, citing cancellation of provisional registration and lack of genuine activities for 12AB, and the denial of 12AB registration as the sole reason for rejecting 80G.

What were the issues?

Whether the CIT(E) correctly rejected the applications for registration and approval, and if the assessee was afforded natural justice. The maintainability of the application under section 12A(1)(ac)(iii) given the status of provisional registration was also an issue.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G,Section 12A(1)(ac)(iii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri Kuldip Singh & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

These two appeals by the assessee are directed against two separate orders of the learned Commissioner of Income Tax (Exemption), Jaipur [“the CIT(E)”], both passed in Form No. 10AD and both dated 25.09.2025, rejecting respectively the assessee’s application for registration under section 12AB and its application for approval under section 80G of the Income Tax Act, 1961 [“the Act”]. Since the two orders arise from the same set of facts, and the rejection under section 80G is founded solely

ITA No. 767 & 762/JPR/2026 Nalanda Foundation Marudhara upon the rejection under

The order continues below.

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