RAVIWAR KARANJA GANESHOTSAV MANDAL,NASHIK vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE

INCOME TAX APPELLATE TRIBUNAL, PUNE BENCH, PUNE BENCH: B BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND DR. DIPAK P. RIPOTE, ACCOUNTANT MEMBER

ITA 1057/PUN/2026 Permanent Account Number: AAATR7971D RAVIWAR KARANJA COMMISSIONER OF GANESHOTSAV MANDAL INCOME TAX (EXEMPTION) RAVIWAR KARANJA GANESHOTSAV MANDAL, ROOM NO. 322, 3RD FLOOR, INCOME TAX 759, GANESH TEMPLE, Vs. OFFICE, PMT BUILDING, RAVIWAR KARANJA., SHANKARSHETH ROAD. PUNE-411037, NASHIK-422001, MAHARASHTRA MAHARASHTRA (प्रत्यर्थीRespondent) (अपीलार्थीAppellant)

निर्धारितीद्वधिध/Assessee Smt. Deepa Khare.AR (Virtual) represented by: िधजस्‍वद्वधिध/Revenue represented Shri Himanshu Sharma CIT- by: DR.

सुिवधई की तधिीख/Date of hearing: 06-07-2026 घोषणध की तधिीख/Date of pronouncement: 13-07-2026 ORDER PER PAVAN KUMAR GADALE, JUDICIAL MEMBER: The assessee has filed the appeal against the order of the Commissioner of Income Tax (Exemptions)(CIT(E)), Pune passed u/sec 80G of the Act. The assessee has raised the grounds of appeal challenging the order of the CIT (E) rejecting the application filed for registration u/sec 80G of the Act.

ITA 1057/PUN/2026 RaviwarKaranjaGaneshotsav Mandal 2. The brief facts of the case are that, the assessee is a registered trust and is engaged in charitable activities u/sec 2(15) of the Act. The assessee was granted provisional approval u/sec80G of the Act dated 8.02.2022 in form No. 10AC. Subsequently, as per the amended provisions of Section80G(5)of the Act, the assessee for the purpose of permanent registration has uploaded e- application in Form No. 10AB on 17.07.2025 and since there was no proper compliance by the assessee to the notice of hearing and the CIT(E) has observed that the assessee has not complied with the provisions of section80G(5) of the Act and expenditure on religious activities is more than 5% of the total income and has rejected the application vide order dated17.01.2026. Aggrieved, by the order, the assessee has filed the appeal before the Hon'ble Tribunal. 3. At the time of hearing, the Ld. AR submitted that the CIT(E) has erred in rejecting the assesse’s application ignoring the submissions made along with the application in Form.10AB and the notices of hearing and the assessee has filed the details as called for. Further the Ld.AR submitted that the religious expenditure does not pertain to any specific activities but classified separately. The Ld.AR mentioned that the assesse has a good case on merits and prayed for an opportunity before the lower authorities. Per contra, the Ld.DR relied on the order of the CIT(E). 4. We have heard the rival submissions and perused the material available on record. The assessee has filed the application before the CIT(E) for permanent approval under section 80G of the Act, whereas the CIT(E) in course of hearing proceedings has issued e- notice on the assessee through ITBA portal for certain clarifications and additional information to verify the genuineness of the activities of the trust. Since there was no proper response to the notices in spite of providing sufficient opportunities to the assessee, the CIT(E) has rejected the application. Whereas the Ld.AR submitted that the notices sent by the office of the CIT(E)

ITA 1057/PUN/2026 RaviwarKaranjaGaneshotsav Mandal was complied and the expenditure does not pertains to any specific religious activities but classified separately and prayed for opportunity to explain the facts. Hence we considering, the facts, submissions and the principles of natural justice shall provide with one more opportunity of hearing to the assesse to substantiate the case along with evidences and information. Accordingly, we set aside the impugned order and direct the CIT(E) to denovo consider the application as per the law and we allow the grounds of appealof the assessee for statistical purposes. 5. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on the open Court on 13th July, 2026.

Sd/- Sd/- DIPAK P. RIPOTE PAVAN KUMAR GADALE (ACCOUNTANT MEMBER) (JUDICIAL MEMBER) Pune; दिन ांक / Dated: 13th July, 2026 Abhishek Digitally signed by Abhishek Abhishek Mohan Mohan Date: 2026.07.14 10:36:16 +05'30' आिेश की प्रतितिति अग्रेतिि / Copy of the Order forwarded to : अिीि र्थी / The Appellant. 1. प्रत्यर्थी / The Respondent. 2. 3. The Pr. CIT concerned. 4. तिभ गीय प्रतितनति, आयकर अिीिीय अतिकरण, “B” बेंच, पुणे/ DR, ITAT, “B” Bench, Pune. ग र्डफ़ इि / Guard File. 5. //True Copy//

आिेश नुस र / BY ORDER,

Assistant Registrar आयकर अिीिीय अतिकरण, / ITAT, Pune