LAVEENA VIKAS SEVA SANSTHAN,UDAIPUR vs. CIT EXEMPTION, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR “A” BENCH, JAIPUR (PHYSICAL HEARING) BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI KULDIP SINGH, JUDICIAL MEMBER ITA No: 46 & 47/JPR/2026

Laveena Vikas Seva CIT(Exemption), Sansthan Jaipur. Vs (Respondent) Laveena Public Boarding inside Rajasthan Vidyapeeth School, Police Station Road, Jhadol, Udaipur. PAN: AAATL5223C (Appellant) Assessee Represented: None Revenue Represented: Shri Ananad Swaroop, CIT Date of hearing : 04-08-2026 Date of pronouncement : 10-08-2026 ORDER PER : KULDIP SINGH, JUDICIAL MEMBER:-

Appellant- Laveena Vikas Seva Sansthan by filing the aforesaid connected appeals sought to set aside the impugned orders passed by Commissioner of Income Tax (Exemption), Jaipur (hereinafter referred to as the ‘CIT(E)’] both dated28.11.2025 dismissing its applications for registration under section 12AB and 80G of the

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Income Tax Act, 1961 (hereinafter referred to as the “Act”) on the grounds inter-alia that:- ITA No. 46/JPR/2026 “Ground1. That under the facts and circumstances of the case, the Ld. CIT, Exemption grossly erred in rejecting the application in Form 10AB for renewal of the registration under section 80G of 2 the Income Tax Act, 1961, merely based on assumptions, surmises and conjectures and against the principles of natural justice and hence the same may kindly be quashed and the renewal shall be granted. Ground2. The Ld. CIT Exemption erred in law as well as on the facts of the case in rejecting the Application No. CIT EXEMPTION, CIT EXEMPTION, JAIPUR/2025-26/12AA/10884 for granting registration/approval u/s 80G. The rejection so made and refusal to grant Registration/approval u/s 80G is contrary to the provisions of law and facts of the case. The same kindly may be quashed and the renewal shall be granted. Ground3. The Ld. CIT Exemption grossly erred in assuming that Incomplete Form 10AB was filed not considering the fact that 4 the appellant trust filed its application in Form 10AB well within Rs time and provided all the documents as required and accepted in Form 10AB on the Income Tax Portal as on 27th May 2025 Ground4. The Ld. CIT Exemption grossly erred in assuming that the appellant trust is not registered under Rajasthan Public Trust Act, 1959 whereas the facts of the case is that the trust is 5 registered under Rajasthan Public Trust Act, 1959 vide registration no. 24/TRUST/DEV/UDAI/2024. Thus the renewal under section 80G may please be granted and the rejection order passed by Ld. CIT, Exemption may please be quashed. Ground5. That the impugned order so passed was in the 6 contravention of the law prevalent at the relevant point of time and also on fact and hence may kindly be quashed. Ground6. The appellant trust has already been granted registration/approval u/s 80G based on same facts and circumstances and no facts OR circumstances have been changed since then in the working of the appellant trust and thus rejecting the application for

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renewal is nothing but merely a change of opinion and hence the impugned order may kindly be quashed. Ground7. The appellant prays your honour indulgences to add, 1 amend OR alter of OR any of the grounds of the appeal on OR before the date of hearing.”

ITA No. 47/JPR/2026 “Ground1. That under the facts and circumstances of the case, the Ld. CIT, Exemption grossly erred in rejecting the application in Form 10AB for renewal of the registration under section 12AB 1 of the Income Tax Act, 1961, merely based on assumptions, surmises and conjectures and against the principles of natural justice and hence the same may kindly be quashed and the renewal be granted.

Ground2. The Ld. CIT Exemption erred in law as well as on the facts of the case in rejecting the Application No. CIT EXEMPTION, JAIPUR/2025- 26/12AA/10876 for granting registration/approval u/s 12AA. The rejection so made and refusal to grant Registration/approval u/s 12AA is contrary to the provisions of law and facts of the case. The same kindly may be quashed and the renewal shall be granted.

Ground3. The Ld. CIT Exemption grossly erred in assuming that Incomplete Form 10AB was filed not considering the fact that 3 the appellant trust filed its application in Form 10AB well within Rs. time and provided all the documents as required and accepted in Form 10AB on the Income Tax Portal as on May 2025

Ground4. The Ld. CIT Exemption grossly erred in assuming that the appellant trust is not registered under Rajasthan Public Trust Act, 1959 whereas the facts of the case is that the trust is 4 registered under Rajasthan Public Trust Act, 1959 vide registration no. 24/TRUST/DEV/UDAI/2024. Thus the renewal under section 12AA may please be granted and the rejection order passed by Ld. CIT, Exemption may please be quashed.

Ground5. That the impugned order so passed was in the 5 contravention of the law prevalent at the relevant point of time and also on fact and hence may kindly be quashed.

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Ground6. The appellant trust has already been granted registration/approval u/s 12AA based on same facts and circumstances and no facts or circumstances have been changed Rs since then in the working of the appellant trust and thus rejecting the application for renewal is nothing but merely a change of opinion and hence the impugned order may kindly be quashed.

Ground7. The appellant prays your honour indulgences to add, amend OR alter of OR any of the grounds of the appeal on OR before the date of hearing.”

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hence, dismissed the applications by incorporating in the reasons inter-alia that:-  Incomplete form 10AB.  Non registration with RPT Act, 1959.  Non Genuineness of Activities and non compliance.

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Sd/- Sd/- (ANNAPURNA GUPTA) (KULDIP SINGH) ACCOUNTANT MEMBER JUDICIAL MEMBER Jaipur Dated:- 10/08/2026. *Santosh. Copy of the order forwarded to: 1. The Appellant- 2. The Respondent- 3. CIT 4. CIT(A) 5. DR, ITAT, Jaipur. 6. Guard File By order,

Asst. Registrar