MADHAVI RAKSHA SANKALPA,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (EXEMPTIONS)-CIRCLE 2, MUMBAI, MUMBAI

Briefly stated, the facts are that the assessee is a religious- cum-charitable trust, which has been in existence for several decades. The trust was originally granted registration under section 12A vide order dated 05.09.1986. Consequent to the introduction of the new registration regime, the assessee was also granted registration under section 12A(1)(ac) vide Form No.10AC dated 24.09.2021. Thereafter, the assessee filed Form No.10AB seeking renewal of registration under section 12AB within the prescribed period.

During the course of proceedings, the learned CIT(E) issued a notice dated 14.11.2025 calling upon the assessee to furnish various details relating to its registration, trust deed,

However, the learned CIT(E), vide the impugned order, rejected the application by observing that the application was incomplete and that the assessee had failed to furnish sufficient documentary evidence to substantiate the genuineness of the expenditure incurred towards its objects. According to the learned CIT(E), the assessee had not furnished independent or corroborative evidence to establish

Before us, the learned Counsel for the assessee submitted that the very foundation of the impugned order is factually incorrect. He drew our attention to the notice dated 14.11.2025 as well as the detailed reply dated 25.11.2025 and submitted that every query raised by the learned CIT(E) had been specifically answered and supported by documentary evidence. He further invited our attention to the index of the paper book, demonstrating that all the documents forming part of the reply had also been filed before the learned CIT(E). It was submitted that despite the extensive material placed on record, the learned CIT(E) neither examined the documents objectively nor pointed out any specific deficiency therein. The rejection, therefore, proceeds merely on generalized observations without identifying any material defect or discrepancy. It was accordingly contended that since all relevant materials were already available before the learned CIT(E), no useful purpose would now be served by remanding the matter and an appropriate direction deserves to be issued for grant of registration under section 12AB.

On the other hand, the learned Departmental Representative relied upon the findings recorded by the

We have given our thoughtful consideration to the rival submissions and have carefully examined the entire material available on record.

The core issue requiring adjudication is whether the learned CIT(E) was justified in rejecting the assessee’s application for renewal of registration under section 12AB on the premise that the application was incomplete and that the assessee had failed to establish the genuineness of its activities by furnishing supporting documentary evidence.

From the record, we find that the assessee is not a newly constituted trust seeking registration for the first time. It has been enjoying registration under section 12A since 05.09.1986 and, pursuant to the introduction of the new registration regime, was also granted registration in Form No.10AC dated 24.09.2021. Thereafter, the assessee filed Form No.10AB seeking renewal of registration. During the

The paper book demonstrates that the assessee had furnished copies of the original registration granted under section 12A, registration granted under Form No.10AC, Form No.10AB, the trust deed together with amendments approved by the Charity Commissioner, details of trustees along with their KYC documents, audited financial statements, income- tax returns, Charity Commissioner certificate, bank account details, details of fixed assets, investments and fixed deposits, details regarding corpus donations, explanatory notes regarding the activities undertaken by the trust, photographs depicting charitable activities, documentary references, extracts from publications, newspaper articles, links to documentaries, details explaining the Yogeshwar Krishi movement, environmental conservation activities, rainwater harvesting projects, village welfare programmes, assistance

Despite the aforesaid factual position, the learned CIT(E) has rejected the application primarily on the ground that the application was incomplete and that the assessee had failed to furnish documentary evidence substantiating the genuineness of its activities. We find ourselves unable to concur with the said conclusion. Neither from the impugned order nor from the show-cause notice does it emerge that the learned CIT(E) had identified any particular document which remained unfiled or any specific information which continued to remain deficient after receipt of the assessee’s reply dated 25.11.2025. Even in the impugned order, there is no discussion as to why the documentary material already placed on record was unacceptable or insufficient. No discrepancy has been pointed out in the audited accounts, no defect has been noticed in the trust deed, no adverse material has been brought on record against the trustees or the functioning of the trust and no finding has been recorded that the activities reflected in the documents were either sham or

Equally important is the fact that the learned CIT(E) has observed that the assessee had failed to substantiate the authenticity of expenditure incurred on its objects. However, except making such a general observation, no expenditure has been identified which, according to the learned CIT(E), required any further verification. The reply filed by the assessee contains detailed explanations regarding the nature of its activities, the manner in which corpus donations are received and utilized, the charitable and religious programmes undertaken across various villages, the audited financial statements and the supporting documentary evidence. Once such material had been furnished, it was incumbent upon the learned CIT(E) either to objectively examine the same or, if still not satisfied, to call upon the assessee to furnish any further specific clarification. The learned CIT(E), however, has neither undertaken such an exercise nor afforded any further opportunity after considering the reply already filed. The conclusion that the genuineness of activities stood unestablished, therefore, does not flow from any objective appreciation of the material available on record.

We also cannot lose sight of the fact that this is not a case where the assessee was seeking registration for the first time. The trust has been in existence for several decades and has continuously enjoyed registration under the Act. It had also been granted registration under the new regime in Form No.10AC after examination by the Department itself. During the present proceedings, the assessee has placed on record complete details regarding its constitution, objects, activities,

In view of the foregoing discussion and having regard to the entirety of the material placed before us, we are satisfied that the assessee had duly complied with the notice issued by the learned CIT(E) by furnishing all relevant documents and explanations sought from it. The findings recorded in the impugned order are contrary to the record and are based on an erroneous factual assumption that the assessee had failed to furnish the requisite material. Since no adverse finding survives either with regard to the objects of the trust or the genuineness of its activities, we do not find it to be a fit case for restoring the matter once again to the file of the learned CIT(E). The impugned order dated 25.03.2026 is accordingly set aside and the learned CIT(E) is directed to grant renewal of registration to the assessee under section 12AB of the Income-tax Act, 1961, in accordance with law. The grounds raised by the assessee are allowed.