SHRI JAIN RATNA HITESHI SHRAWAK SANGH,JODHPUR vs. CIT(EXEMPTION), JAIPUR

PDF · subscribers
ITA 203/JODH/2025Status: DisposedITAT Jodhpur07 August 20263 pages
AI SummaryAllowed

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?

Section 80G,Section 12A,Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JODHPUR BENCH, JODHPUR

For Appellant: Shri Amit Kothari CA, (Physically)
For Respondent: Ms. Shivani Bansal, CIT-DR

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’).

2.

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.

3.

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

All 6,482 judgments and leading authorities on Section 80G →

Recent GST High Court judgments

Search GST case law →