JLF BLESSED HOME FOUNDATION,JAIPUR vs. CIT-EXEMPTION, JAIPUR, JAIPUR

IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR “A” BENCH, JAIPUR (PHYSICAL HEARING) BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI T. R. SENTHIL KUMAR, JUDICIAL MEMBER

ITA No: 251 & 252/JPR/2026

JLF Blessed Home Foundation Vs. The CIT-Exemption, F-51, Balaji Tower-1, Near Jaipur Manipal Hospital, Vidhyadhar Nagar Sikar Road, Jaipur. PAN No.: AAGCJ6819F Appellant Respondent Assessee Represented: Shri Shrawan Kumar Gupta, Adv. Revenue Represented: Shri Ananad Swaroop, CIT : 22/07/2026 Date of Hearing : 29/07/2026 Date of Pronouncement ORDER PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:- These two appeals are filed by the Assessee trust as against separate orders both dated 31.01.2026 passed by the Commissioner of Income Tax (Exemption), Jaipur (in short referred to as “CIT(E)”), denying registration under section 12AB and 80G(5) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. The assessee is a trust filed application in Form No. 10AB seeking registration under section 12A(1)(ac)(iii) of the Act and also for registration under section 80G(5) of the Act on

ITA No.251 & 252/JPR/2026 JLF Blessed Home Foundation vs. CIT(E) 09.09.2025. Ld. CIT(E) issued two notices on 05.11.2025 and 19.12.2025 calling for various details and the activities carried out by the trust. However the assessee trust failed to comply with the above two notices, which has resulted in passing ex- parte orders denying registration under 12AB and 80G of the Act as well as cancelling the provisional registration granted to the trust.

ITA No. 251/JPR/2026

“1. The Impugned order u/s 12AB of the Act dated 13.01.2026 is bad in law and on facts, without providing adequate & reasonable opportunity of being heard, being without jurisdiction and for various other reasons and hence the same may kindly be quashed. 2. The La. CIT(E) grossly erred in law as well as on the facts of the case in rejecting the application for grant Registration/approval u/s 12AB and in not granting Registration/approval on the incorrect allegations of Incomplete Form 10AB, Non- Registration under the Rajasthan Public Trust Act, 1959, and Non-Genuineness of activities/Non-compliance, without considering the material available on record in their true perspective and sense. The rejection so made and refusal to grant Registration/approval u/s 12AB is contrary to the provisions of law and facts of the case. The same may kindly be quashed. 3. The Ld. CIT(E) has also grossly erred in law as well as on the facts of the case in also cancelling the provisional registration under clause (vi) of clause (ac) of sub section 1 of section 12A of the Act, on the grounds that the assessee failed to provide justification for regularisation without considering the material available on record in their true perspective. The rejection so made and provisional Registration so cancelled is contrary to the provisions of law and facts of the case and against the principal of law and against the principal of natural justice. The same may kindly be quashed and directed to the Ld. CIT(E) to restore the Provisional registration also. 4. That the impugned order so passed was in the contravention of the taw prevalent of the relevant point of time and also on fact and hence

ITA No.251 & 252/JPR/2026 JLF Blessed Home Foundation vs. CIT(E) may kindly be quashed. The Id. CIT(E) be directed to grant Registration/approval from the dated of application. 5. The appellant prays your honour indulgences to add, amend or alter of or any of the grounds of the appeal on or before the hearing.” ITA No. 252/JPR/2026

“1. The Impugned order u/s 80G of the Act dated 13.01.2026 is bad in law and on facts, without providing adequate & reasonable opportunity of being heard, being without jurisdiction and for various other reasons and hence the same may kindly be quashed. 2. The Ld. CIT(E) grossly erred in law as well as on the facts of the case in rejecting the application for grant Registration/approval u/s 80G and in not granting Registration/approval on the incorrect allegations as 12AB application is rejected on the ground of incomplete Form 10AB, Non-Registration under the Rajasthan Public Trust Act, 1959, and Non- Genuineness of activities/Non-compliance without considering the material available on record in their true perspective and sense. The Ld. CIT(E) erred in not considering the merits of the 80G application independently and based on incorrect allegations regarding the 12AB proceedings. 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 may kindly be quashed. 3. The Ld. CIT(E) also erred in cancelling the provisional approval u/s 80G(5) dated 15.03.2025 without valid cause. The impugned order so passed was in the contravention of the law prevalent at the relevant point of time and also on fact and hence may kindly be quashed. The Ld. CIT(E) be directed to grant Registration / approval from the date of application. 4. 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.” 4. Learned counsel appearing for the assessee submitted that trust is prepared to file all relevant documents required before Ld. CIT(E) if one more opportunity of hearing be given to the assessee trust. 5. Per contra, Ld. CIT-DR appearing for the Revenue strongly opposed the above submission of the assessee, since two

ITA No.251 & 252/JPR/2026 JLF Blessed Home Foundation vs. CIT(E) opportunities of hearing given to the trust, which was not replied by it. 6. We have given our thoughtful consideration and perused the materials available on record. Since Ld. counsel under takes to file all relevant documents and evidences before Ld. CIT(E), if one more opportunity of hearing given to the assessee trust. Considering the above submission of the assessee and to meet the ends of Justice, we deem it fit to impose a cost of Rs. 5,000/- each payable by the assessee trust to the Income Tax Department within two weeks of receipt of copy of this order. On production of the payment of cost, before Ld. CIT(E), the ex- parte orders passed by Ld. CIT(E) are hereby set aside with a direction to given one more opportunity of hearing to the assessee trust for registration under section 12AB and 80G(5) of the Act. Needless to say, the assessee should make use of this final opportunity and produce all relevant materials, documents and evidences before Ld. CIT(E) for granting registration. In the result, the appeals filed by the assessee are 7. allowed for statistical purposes. Order pronounced in the open court on 29/07/2026.

Sd/- Sd/- (ANNAPURNA GUPTA) (T.R. SENTHIL KUMAR) ACCOUNTANT MEMBER JUDICIAL MEMBER Jaipur Dated:- 29/07/2026. *Santosh 4

ITA No.251 & 252/JPR/2026 JLF Blessed Home Foundation vs. CIT(E) Copy of the Order forwarded to: 1. The Assessee The Revenue 2. 3. Concerned CIT 4. CIT(A) 5. DR, ITAT, Jaipur. 6. Guard File By order,

Asst. Registrar