SHRI JAIN RATNA HITESHI SHRAWAK SANGH,JODHPUR vs. CIT(EXEMPTION), JAIPUR
What did the Tribunal hold?
The Tribunal found that the assessee had valid registrations under Sections 12A and 12AB, which dispelled doubts about the genuineness of its activities. Therefore, the CIT(E)'s order was set aside.
What were the facts?
The assessee, a religious and charitable trust, applied for approval under Section 80G of the Income Tax Act. The CIT(E) rejected the application citing non-genuineness of activities, the trust being for the Jain religious community, and religious trusts not being eligible under Section 80G(5).
What were the issues?
Whether the CIT(E) was justified in rejecting the Section 80G approval application based on the grounds raised, especially in light of the assessee's existing registrations.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR
PER: SHRI SAKTIJIT DEY; V.P. :
Present appeal has been filed by the assessee challenging the order dated 25-12-2024 passed by learned Commissioner of Income Tax (Exemption) [in short, ‘CIT-(E)’, Jaipur, rejecting assessee's application seeking approval under Section 80G of the Income Tax Act, 1961 (in short ‘the Act’).
We have heard the parties and perused the materials on record. A reading of the impugned order of learned CIT(E) reveals that assessee's
2 ITA No. 203 /Jodh/2025 (Assessment Year: NA) application seeking approval under Section 80G of the Act was rejected on the following grounds:
i. Non-genuineness of the activities. ii. Trust for benefit of Jain religious community. iii. Religious Trusts are not eligible under Section 80G(5).
However, material placed on record reveal that not only assessee is registered under Section 12A of the Act as a religious asnd charitable Trust but in a recent order passed on 17-02-2026, registration under Section 12AB(1)(b) has been extended to the assessee up to Assessment Year 2036-37. Thus, the fresh registration granted to the assessee, as noted above, completely dispels the doubt expressed by learned CIT(E) with regard to non-genuine activities of the assessee and the nature of the Trust.
In view of the aforesaid, we set aside the impugned order of learned CIT(E) with a direction to grant approval to the assessee under Section 80G of the Act. 4. In the result, appeal is allowed.
Order pronounced in open court on 07/08/2026.
Sd/- Sd/- (Saktijit Dey) (Makarand Vasant Mahadeokar) Accountant Member Vice President
Dated : 07/08/ 2026.
3 ITA No. 203 /Jodh/2025 (Assessment Year: NA) AKS/- True Copy Copies to : (1) The appellant. (2) The respondent. (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File
BY ORDER,
More judgments on Section 80G
- Savan Dayalal Ladani, Rajkot vs Assistant Commissioner of Income Tax-2(1)…ITA 575/RJT/2026[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Pareshbhai Savjibhai Khunt, Rajkot vs Income Tax Officer Ward - 2(2)(3), RajkotITA 842/RJT/2025[2019-20]Status: Disposed19 Oct 2026AY 2019-20
- Gillette India Limited, Mumbai vs Principal Commissioner of Income Tax, JaipurITA 1316/JPR/2026[2018-19]Status: Disposed16 Oct 2026AY 2018-19
- Global University Foundation, Hyderabad vs CIT(Exemption), HyderabadITA 777/HYD/2026[2026-27]Status: Disposed16 Oct 2026AY 2026-27
- Global University Foundation, Hyderabad vs CIT(Exemption), HyderabadITA 776/HYD/2026[2026-27]Status: Disposed16 Oct 2026AY 2026-27
Recent GST High Court judgments
Search GST case law →- M/S. Middlex, Puri vs. Commnr. Of State Tax, Banijyakar Bhawan, CuttackOrissa · 14 Oct 2026
- M/S Maa Sunadei Indane Gramin Vitrak, Nayagarh vs. Commissioner Of CT And GST, Cuttack, OdishaOrissa · 14 Oct 2026
- Sunanda Raul vs. The Commissioner Of Commercial Taxes And Goods Nad Services Tax, OdishaOrissa · 14 Oct 2026
- Zakir Hussain Ali Khan vs. Additional Commissioner (Appeals), BhubaneswarOrissa · 14 Oct 2026
- M/S Manorama Nayak, Khorda vs. Assistant Commissioner Of State Tax, CT And GST, Bhubaneswar Iv Circle, KhurdaOrissa · 14 Oct 2026