RAM BHAGAT HANUMAN MANDIR SAMITI,VPO KHARAK PUNIA vs. CIT EXEMPTIONS, CHANDIGARH, CHANDIGARH

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘G’, NEW DELHI Before Sh. Yogesh Kumar US, Judicial Member & Smt. Renu Jauhri, Accountant Member ITA No. 8357/Del/2025 : Asstt. Year : 2026-27 Ram Bhagat Hanuman Mandir Samiti Vs CIT(Exemptions), VPO Kharak Punia, Tehsil Barwala, Chandigarh-160017 District Hisar, Haryana-125121 (APPELLANT) (RESPONDENT) PAN No. AAEAR3417M Assessee by : Sh. Rajesh Kumar, Adv. Revenue by : Sh. Mahesh Kumar, CIT-DR Date of Hearing: 29.04.2026 Date of Pronouncement: 29.04.2026 ORDER Per Renu Jauhri, Accountant Member: The above captioned appeal is preferred by the assessee against the order dated 09.12.2025, passed by CIT(Exemption), Chandigarh u/s 12A(1)(ac)(ii) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for A.Y. 2026-27.

2 ITA No. 8357/Del/2025 Ram Bhagat Hanuman Mandir Samiti 3. That the Ld. CIT Exemption failed to appreciate that in absence of any allegation of misuse/diversion or violation, renewal could not have been refused. 4. That the Ld. CIT Exemption failed to appreciate the practical circumstance that temple and religious activities in rural/semi-urban areas are dependent upon vendors who deal only in cash. 5. That the Ld. CIT Exemption failed to appreciate that institutional bank accounts of societies are operated under dual/collective signatures and banks generally do not extend UPl/Google Pay facility to such institutional accounts, the only banking mode is cheque, which rural vendors do not accept, making cash expenditure unavoidable and bona fide. Rejection based solely on cash is therefore untenable. 6. That mere mode of expenditure cannot form legal basis for refusing renewal, especially when genuineness and charitable intent are not doubted. 7. That the rejection order is contrary to the settled law laid down by Honorable Supreme Court in Ananda Social & Educational Trust and by Honorable P&H High Court in Surya Educational & Charitable Trust that at renewal stage, only genuineness and charitable objects are to be examined. 8. It is therefore prayed that the impugned order be quashed and renewal u/s 12AB be granted."” 3. Brief facts of the case are that the assessee trust filed an application for registration u/s 12A(1)(ac)(ii) on 20.08.2025. Ld. CIT(E) issued a notice seeking documents to establish the nature and genuineness of charitable activities. On perusal of reply filed by the assessee, ld. CIT(E) sought further information regarding multiple cash transactions from assessee's bank a/c and asked it to furnish documentary evidences to substantiate that the expenses were made for charitable activities. Since the documentary evidences and

3 ITA No. 8357/Del/2025 Ram Bhagat Hanuman Mandir Samiti explanation filed by the assessee were not found to be satisfactory, ld. CIT(E) rejected the assessee's application vide order dated 09.12.2025. Aggrieved, the assessee is in appeal before the Tribunal.