GURU NANAK TRUST OF EDUCATION THROUGH ITS MANAGING TRUSTEE SUKHWANT SINGH,AMRITSAR vs. THE COMMISSIONER OF INCOME-TAX (EXEMPTIONS), CHANDIGARH

ITA 392/ASR/2025Status: DisposedITAT Amritsar10 August 2026AY 2025-20265 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that running a school is a charitable activity. It remanded the matter back to the CIT (Exemptions) for fresh consideration, directing the assessee to provide all documentary evidence and cooperate with the proceedings.

What were the facts?

The assessee trust applied for registration under Section 12(1)(ac)(vi) of the Income Tax Act to run a school. The CIT (Exemptions) rejected the application, doubting the genuineness of activities and financial integrity due to cash deposits from alleged donations from abroad.

What were the issues?

Whether the rejection of registration for a charitable trust running a school was justified, and if principles of natural justice were followed.

Which sections of the Income-tax Act were involved?

Section 12(1)(ac)(vi),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

Hearing: 20.07.2026Pronounced: 10.08.2026

Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of the Ld CIT (E), Chandigarh, dated 20/03/2025, rejecting the application for registration dated 04/09/2024, filed by the assessee in Form 10AB, u/s 12(1)(ac)(vi)(B) of the Income Tax Act 1961(henceforth the Act).

2.

The grounds of appeal taken in Form No. 36 are as follows:

“1. That the order of Ld. Commissioner of Income-tax (Exemptions) is illegal, arbitrary and contrary to facts and on this illegality pervades over all grounds of appeal.

2.

That the Ld. Commissioner of Income-tax (Exemptions) has erred in law and not judicially applied her mind to the facts and circumstances of the case and as such the rejection of reg

The order continues below.

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