GAYATRI SEVA SANSTHAN,UDAIPUR vs. ITO (EXEMPTION), UDAIPUR, UDAIPUR

ITA 576/JODH/2026Status: DisposedITAT Jodhpur20 August 2026AY 2026-2718 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the scope of enquiry at the stage of granting registration is limited to the objects and prima facie genuineness of activities. Deficiencies in documentation, without positive material disproving genuineness, cannot be the sole ground for rejection.

What were the facts?

The assessee, a charitable institution, applied for registration under section 12AB and approval under section 80G. The CIT(E) rejected both applications, citing incomplete documentation, unverified activities, and opaque financial affairs, particularly noting the maintenance of 32 bank accounts with only one statement provided.

What were the issues?

Whether rejection of registration under section 12AB and consequent rejection of approval under section 80G were justified based on perceived deficiencies in documentation and verification of activities.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH JODHPUR

Before: SHRI SAKTIJIT DEY & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Prateek Jain, CA and Shri Gourav, CA (Physically)
For Respondent: Ms. Shivani Bansal, CIT-DR (Physically)
Hearing: 06.08.2026Pronounced: 20.08.2026

PER: MAKARAND VASANT MAHADEOKAR, AM

These two appeals filed by the assessee arise from two separate orders, both dated 25.03.2026, passed by the learned Commissioner of Income Tax (Exemption), Jaipur [“CIT(E)”], in Form No. 10AD. Since both appeals involve common facts and the rejection of approval under section 80G is consequential to the rejection of registration under section 12AB of the Income-tax Act, 1961 [“the Act”], they were heard together and are being disposed of by this common order.

2.

The grounds raised by the assessee in ITA No. 576/Jodh/

The order continues below.

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