ONE WORLD TRUST VASUDHAIVA KUTUMBAKAM,AJMER vs. CIT EXEMPTION, JAIPUR, JAIPUR
What did the Tribunal hold?
The Tribunal set aside the order of the CIT(E) and remanded the matter back to the CIT(E) to provide one more opportunity of hearing to the assessee. The assessee was directed to produce all relevant documents for granting registration.
What were the facts?
The assessee trust applied for registration under sections 12AB and 80G of the Income Tax Act. The CIT(E) denied registration and cancelled provisional registration due to partial compliance with notices and issues with the Rajasthan Public Trust Act registration and genuineness of activities.
What were the issues?
Whether the denial of registration under sections 12AB and 80G was justified, and whether the assessee was granted a proper opportunity of being heard.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR
Before: Shri T.R. Senthil Kumar & Shri Prakash
PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-
These two appeals are filed by the assessee as against separate orders both dated 22.12.2024 passed by the Commissioner of Income Tax (Exemption), Jaipur (in short referred to as ‘CIT(E)’), denying registration u/s 12AB and 80G(5) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).
I.T.A Nos. 330 & 329/JPR/2025 Page No 2
The assessee is a trust filed application in Form No. 10AB seeking registration under section 12A(1)(ac)(iii) of the Act and also for registration under section 80G(5) of the Act on 29.06.2022. Ld. CIT(E) issued three notices calling for various details and the activities carried out by the trust. However the assessee trust partly complied with the above notices, which has resulted in passing orders denying registration under 12AB and 80G of the Act as well as cancelling the provisional registration granted to the assessee trust on account of non-registration under RPT Act, 1956 and Non-Genuineness of the activities.
Aggrieved against the same assessee trust is in appeal before us arising on the following Grounds of Appeal:- 1) It is humbly requested that the trust is working with the objects of public charity i.e. to encourage the common man for sports, and prepare world class mission of sports, healthcare, physical fitness, maintain and construct the sports training centres, provide education, develop the future sportspersons, etc. for all students, lower cadre person, etc irrespective of caste, creed, colour, gender, etc. The charitable objective for the of the trust can be verified from the trust deed, which is already uploaded at the Income Tax Portal. The copy of trust deed is enclosed. 2) The trust commenced its charitable, social welfare, educational activities, development of sports centres, where the trust holds meditation as well as spiritual sessions for development of the mental wellbeing of its students, and also works in the research and development of the spiritual scriptures so that the ancient Indian techniques used in sports are other area in which trust works can be well incorporated with modern day techniques. The trust, and all the persons associated with the trust respects every religion and train and educate all its students irrespective of any caste and creed, without any biasness. The trust creation objective revolves around the charitable purposes only, trust have no religious biasness toward any class of society. 3) The trust is engaged in charitable activities, welfare of nation by education students and preparing them for sports activities, etc. 4) The assessee has already applied for registration in the Devasthan Vibhag Rajasthan, Ajmer under Rajasthan Public Trust Act, 1959, these facts were ignored by the Commissioner Exemption, and has passed order in against of I.T.A Nos. 330 & 329/JPR/2025 Page No 3 the assesse by cancelling its provisional registration which was granted to the assessee under the provisions of Income Tax Act, 1961. 5) It is humbly requested that the trust maintain regular books of accounts and get them duly audited, it can be verified from income tax portal, where the financials and audit report of the assessee is uploaded. It is also requested that all the donation receipts are utilized for the public welfare and for charitable activities only and there is excess of expenditure over income i.e. Deficit. Which proves that trust have no profit motives. Thus, the trust is working for public welfare only. These facts were also submitted by the assessee before the honourable Commissioner Exemption and the copies of the same were also enclosed. The copy of last 2 years Financials and audit report are enclosed. 6) The assessee has utilized all its donation received for charitable purposes only, and has received all its receipts via online mode, which can be verified from the Form 10 BD filled at Income Tax Portal. 7) Assessee has also submitted the copies of invoice for the expenditures done by the assessee towards the achievement of its objectives, which can be verified from the bank statement which are already submitted by the assessee before the honourable Commissioner Exemption. Bank statements are also enclosed. 8) The assessee has submitted all the requisite details before the honourable Commissioner Exemption as and when required. 9) The CIT Exemption has cancelled the provisional registration granted to the assessee under section 80G(5)(iii), it is further requested that the cancellation of provisional registration was not correct. The assessee is full co-operative with the department, but no opportunity of being heard was granted to the assessee before cancellation of the provisional registration, which is against the principal of natural justice. 10) It is humbly requested to your honour that the order passed by commissioner Exemption was not justified as per the principle of natural justice for cancellation of the provisional registration granted under section 80G(5)(iii) and it is humbly requested to kindly quash the order passed by Commissioner Exemption and sustain the provisional registration granted previously, and grant us the registration so that we may collect donation for conducting the charitable activities and contribute to the welfare of general public. 11) Grounds of appeal may be craved, added, amended, modified, altered during the appeal proceedings before your honour passing the appeal order. “1) It is humbly requested that the trust is working with the objects of public charity i.e. to encourage the common man for sports, and prepare world class
I.T.A Nos. 330 & 329/JPR/2025 Page No 4 mission of sports, healthcare, physical fitness, maintain and construct the sports training centres, provide education, develop the future sportspersons, etc. for all students, lower cadre person, etc irrespective of caste, creed, colour, gender, etc. The objective for the of the trust can be verified from the trust deed, which is already uploaded at the Income Tax Portal. The copy of trust deed is enclosed. 2) The trust commenced its charitable, social welfare, educational activities, development of sports centres, where the trust holds meditation as well as spiritual sessions for development of the mental wellbeing of its students, and also works in the research and development of the spiritual scriptures so that the ancient Indian techniques used in sports are other area in which trust works can be well incorporated with modern day techniques. The trust, and all the persons associated with the trust respects every religion and train and educate all its students irrespective of any caste and creed, without any biasness. 3) The trust is engaged in charitable activities, welfare of nation by education students and preparing them for sports activities, etc. 4) The assessee has already applied for registration in the Devasthan Vibhag Rajasthan, Ajmer under Rajasthan Public Trust Act, 1959, these facts were ignored by the Commissioner Exemption, and has passed order in against of the assesse by cancelling its provisional registration which was granted to the assessee under the provisions of Income Tax Act, 1961. 5) It is humbly requested that the trust maintain regular books of accounts and get them duly audited, it can be verified from income tax portal, where the financials and audit report of the assessee is uploaded. It is also requested that all the receipts are utilized for the public welfare and charitable activities and there is excess of expenditure over income. Thus the trust is working for public welfare only. These facts were also submitted by the assessee before the honourable Commissioner Exemption and the copies of the same were also enclosed. The copy of last 2 years Financials and audit report are enclosed. 6) The assessee has submitted the requisite details before the honourable Commissioner Exemption as and when required. 7) Assessee has also submitted the copies of invoice for the expenditures done by the assessee towards the achievement of its objectives, which can be verified from the bank statement which are already submitted by the assessee before the honourable Commissioner Exemption. Bank statements are also enclosed. 8) The CIT Exemption has cancelled the provisional registration granted to the assessee under section 12A(1)(ac) (iii), it is further requested that the cancellation of provisional registration was not correct. The assessee is full co- operative with the department, but no opportunity of being heard was granted to the assessee before cancellation of the provisional registration, which is against the principal of natural justice. 9) It is humbly requested to your honour that the order passed by commissioner Exemption was not justified as per the principle of natural justice for cancellation of the provisional registration granted under section 12A(1)(ac) (iii) and it is humbly requested to kindly quash the order passed by Commissioner Exemption and sustain the provisional registration granted
I.T.A Nos. 330 & 329/JPR/2025 Page No 5 previously, and grant us the registration so that we may conduct the charitable activities and contribute to the welfare of general public. 10) Grounds of appeal may be craved, added, amended, modified, altered during the appeal proceedings before your honour passing the appeal order.
None appeared on behalf of the assessee, there is no power of attorney in favour of any Authorized Representative. Today is the 15th time of hearing of these appeals. The assessee filed before us, document what was filed before ld. CIT(E) as well as Form no. 7 issued by Assistant Commissioner, Rajasthan Public Trust dated 13.10.2025. It is further noticed that rejection of 80G(5) of the Act at page no. 3, Ld. CIT(E) has wrongly mentioned the name of the assessee as ‘Prayas ek Kadam Society’. Considering the same, we deem it fit to set aside the matter back to the file of ld. CIT(E) to give on one more opportunity of hearing to the assessee. Needless to say, the assessee should make use of this final opportunity and produce all relevant material documents before ld. CIT(E) for granting registration u/s 12AB and 80G(5) of the Act.
In the result, the appeals filed by the assessee are allowed for statistical purposes.
Order pronounced in the open court on 11-08-2026 (PRAKASH) (T.R. SENTHIL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Dated 11/08/2026 *Ganesh Kr., Sr. PS
I.T.A Nos. 330 & 329/JPR/2025 Page No 6 आदेश क" ""त"ल"प अ"े"षत / Copy of Order Forwarded to:-
Assessee
Revenue
Concerned CIT
CIT (A)
DR, ITAT
Guard file. By order/आदेश से,
सहायक पंजीकार आयकर अपील"य अ"धकरण, t;iqj
More judgments on Section 12AB
- Desire Foundation, Jaipur vs Income Tax Officer, JaipurITA 1646/JPR/2026[2024-25]Status: Disposed21 Oct 2026AY 2024-25
- Sheo Narayan Trust, Khajpura vs CIT Exemption, PatnaITA 554/PAT/2026[2025-2026]Status: Disposed16 Oct 2026AY 2025-2026
- Ss Early Learning Society, Hyderabad vs CIT (Exemption), HyderabadITA 1208/HYD/2025[2026-27]Status: Disposed16 Oct 2026AY 2026-27
- Shri Brajshiromani Laxmandas Sewa Trust… vs Income-Tax Officer, Ward 1(3)(1), Mathura…ITA 592/AGR/2026[2026-2027]Status: Disposed14 Oct 2026AY 2026-2027
- Shri Brajshiromani Laxmandas Sewa Trust… vs Income-Tax Officer, Ward 1(3)(1), Mathura…ITA 591/AGR/2026[2026-2027]Status: Disposed14 Oct 2026AY 2026-2027
Recent GST High Court judgments
Search GST case law →- Atiquiddin Shaikh vs. The State Of Madhya PradeshMadhya Pradesh · 16 Oct 2026
- Mr. Gurudev Singh vs. Kotak Mahindra BankMadhya Pradesh · 16 Oct 2026
- Venkadeswara Grill Works vs. The Joint Commissioner (St)Madras · 16 Oct 2026
- Mufti Clothing And Co vs. The Assistant Commissioner (St)Madras · 16 Oct 2026
- U Days Garments vs. The Adjudication OfficerMadras · 16 Oct 2026