MANAV SEVA SAHYATA TRUST,UDAIPUR vs. CIT(E), JAIPUR

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ITA 216/JODH/2025Status: DisposedITAT Jodhpur07 August 20263 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since the assessee was granted registration under Section 12A/12AB and subsequently 80G approval by the CIT, the earlier rejection order was incorrect. The Tribunal set aside the rejection order and directed the grant of 80G approval.

What were the facts?

The assessee, a registered trust, had its application for approval under Section 80G rejected by the CIT(Exemption) due to alleged non-genuineness of activities. The trust had previously held 80G approval and was later granted fresh registration and 80G approval by the same CIT.

What were the issues?

Whether the rejection of 80G approval based on alleged non-genuineness was justified when the trust had valid registrations and subsequent 80G approval.

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

Before: SHRI SAKTIJIT DEY, HON’BLE & SHRI MAKARAND VASANT MAHADEOKAR, HON’BLE

For Appellant: Shri S.V.S. CA (Physically)
For Respondent: Ms. Shivani Bansal, Addl. CIT-DR
Hearing: 03/08/2026

IN THE INCOME TAX APPELLATE TRIBUNAL JODHPUR BENCH, JODHPUR BEFORE SHRI SAKTIJIT DEY, HON’BLE VICE PRESIDENT AND SHRI MAKARAND VASANT MAHADEOKAR, HON’BLE ACCOUNTANT MEMBER

ITA No.123/Jodh/2025 (Assessment Year 2024-25 ) Manav Seva Sahyata Trust, CIT(Exemption), 75, Narpa Nagar, Jaipur Jodhpur - 342008 Vs. PAN No. AAFTM 8508G

ITA No.216/Jodh/2025 (Assessment Year NA ) Manav Seva Sahyata Trust, CIT(Exemption), CA S.V. Khatri, Shri PAD 8-9, Jaipur Near Rajasthan Patrika, Man Ji Vs. Ka Hattha, Paota, Jodhpur- 342006 PAN No. AAFTM 8508G

Assessee by Shri S.V.S. CA (Physically) Revenue by Ms. Shivani Bansal, Addl. CIT-DR (Physically) Date of Hearing 03/08/2026. Date of Pronouncement 07 / 08 / 2026.

ORDER Per: Saktijit Dey, Vice President: This is an appeal filed by the assessee challenging two separate orders passed by learned CIT (Exemption), Jaipur, rejecting assessee’s

2 ITA No. 123/Jodh/2024 ITA No. 216/Jodh/2024 Asst. Year: 2024-25 applications seeking approval under Section 80G of the Income Tax Act, 1961 (in short ‘the Act’).

2.

Briefly the facts are, the assessee is a Trust registered under Section 12A of the Act and registration is continuing till date. The assessee had also received approval under section 80G of the Act earlier. However, subsequently, assessee's application seeking renewal of approval under section 80G of the Act was rejected by learned CIT(Exemption). Subsequently, the assessee again applied for approval under section 80G of the Act. This application was also rejected vide order dated 27-06-2024, alleging non-genuineness of the activities of the assessee.

3.

We have considered rival submissions and perused the materials on record. It is evident that the assessee was originally granted registration under section 12AA of the Act, vide order dated 25-02-2019. Subsequently, the assessee applied for registration under the amended provisions of the Act, and the learned CIT (Exemption), Jaipur, vide order dated 14.02.2026, has not only granted registration to the assessee up to Assessment Year 2031-32 but also granted approval under section 80G of the Act for the Assessment Years 2027-28 to 2031-32. We have also noted that assessee had earlier been granted approval under section 80G of the Act by the competent authority. Thus, when assessee has been granted registration

3 ITA No. 123/Jodh/2024 ITA No. 216/Jodh/2024 Asst. Year: 2024-25 under section 12A/12AB of the Act, there cannot be any doubt regarding the genuineness of the Trust. In view of the aforesaid, we set aside order dated 27-12-2024 passed by learned CIT(Exemption) with a direction to grant approval under section 80G of the Act.

4.

In view of our decision in ITA No.216/Jodh/2024, the other appeal, being ITA No.123/Jodh/2024, has become infructuous hence dismissed. Whereas, ITA No.216/Jodh/2024 is allowed.

Order pronounced in the open court on 07/08/2026. Sd/- Sd/- (Makarand Mahadeokar) (Saktijit Dey) Accountant Member Vice President

Dated : 07/08/2026. Aks/- True Copy Copies to : (1) The appellant. (2) The respondent. (3) CIT (4) CIT(A) (5) Departmental Representative (6) Guard File BY ORDER,

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