SARLA BANSAL TRUST,AMRITSAR vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS), CHANDIGARH
What did the Tribunal hold?
The Tribunal held that the rejection was arbitrary as the assessee was not given an opportunity to explain any shortfall and no show cause notice was issued. The low quantum of activities alone cannot be a ground for rejection.
What were the facts?
The assessee, a charitable trust, applied for re-registration under Section 12A(1)(ac)(ii) and approval under Section 80G. The CIT(E) rejected the applications, citing lack of evidence for charitable activities and donations.
What were the issues?
Whether the rejection of registration and approval applications by the CIT(E) was justified without issuing a show cause notice and providing an opportunity for explanation.
Which sections of the Income-tax Act were involved?
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
Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of the Ld CIT (E), Chandigarh, dated 02/12/2025, rejecting the application for registration dated 21/08/2025 filed by the assessee in Form 10AB, u/s 12A(1)(ac)(ii) of the Income Tax Act 1961 (henceforth the Act).
The grounds of appeal taken by the assessee in the memorandum of appeal in form 36 are as follows: “1.The Learned CIT(E) Chandigarh has wrongly rejected the approval of Re-registration Charitable Trust of for which an application was filed in Form 10AB u/s 12A(1)(ac)(ii) of the Income Tax Act, 1961 from onwards. 1/4/2026 & and onwards.
I.T.A. No.963 and 972/Asr/2025 2 Assessment Year: N/A 2. The Learned
The order continues below.
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- Shri Brajshiromani Laxmandas Sewa Trust… vs Income-Tax Officer, Ward 1(3)(1), Mathura…ITA 592/AGR/2026[2026-2027]Status: Disposed14 Oct 2026AY 2026-2027
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