SHREE MAHAVEER SWAMI PANCHSIKHRI JINALYA TRUST,JALORE vs. CIT(E), JAIPUR, JAIPUR

ITA 888/JODH/2026Status: DisposedITAT Jodhpur13 August 202610 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(E)'s rejection was based on a misconception. The assessee possessed a valid and subsisting regular registration when applying for renewal, making the application under section 12A(1)(ac)(ii) appropriate. The prior selection of an incorrect sub-clause in the regular registration application did not invalidate the subsisting registration.

What were the facts?

The assessee-trust, established in 2018, was granted provisional registration under section 12A(1)(ac)(vi) in May 2021. Subsequently, it obtained regular registration under section 12A(1)(ac)(i) in December 2022. When applying for renewal under section 12A(1)(ac)(ii), the CIT(E) rejected the application, stating the assessee lacked prior registration under section 12A/12AA before April 1, 2021.

What were the issues?

Whether the rejection of a renewal application for registration under section 12AB was justified solely on the ground that the assessee did not have registration prior to April 1, 2021, despite having a valid subsisting registration.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac),Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

For Appellant: CA (Virtual)
For Respondent: DR (Physical)

PER BENCH: The aforesaid appeal has been filed by the assessee against the impugned order dated 14.03.2026 passed by the Ld. Commissioner of Income Tax (Exemption), Jaipur [“Ld. CIT(E)”], whereby the assessee’s application dated 27.09.2025 filed in Form No. 10AB for renewal of registration under section 12AB of the Income-tax Act, 1961 has been rejected.

2.

The sole controversy arising in the present appeal is whether the Ld. CIT(E) was justified in rejecting the application on the ground that the assessee was not Asst. Year: NA registered under section 12A/12AA prior to 01.04.2021 and, therefore, according to him, it could not have applied under clause (ii) of section 1

The order continues below.

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