NAGARAHOLE TIGER CONSERVATION FOUNDATION ,MYSURU vs. COMMISSIONER OF INCOME TAX EXEMPTIONS , BANGALORE

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ITA 2503/BANG/2025Status: DisposedITAT Bangalore27 April 2026AY 2025-263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, considering the assessee's request for another opportunity and the foundation's role in tiger conservation, decided to remit the issue back to the CIT(Exemptions) for a fresh decision. The assessee was directed to produce all relevant documents.

What were the facts?

The assessee, Nagarahole Tiger Conservation Foundation, failed to appear before the CIT(Exemptions) and submit necessary documents for approval under Section 80G. Consequently, the CIT rejected the application.

What were the issues?

Whether the CIT(Exemptions) was justified in rejecting the application for approval under Section 80G without granting a proper opportunity to the assessee. Whether the assessee should be granted a fresh opportunity to present its case.

Which sections of the Income-tax Act were involved?

Section 80G

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A’’BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

Hearing: 19.02.2026Pronounced: 27.04.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of ld.CIT (Exemptions), Bengaluru dated 5.9.2025 vide DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/1080380369(1) rejecting approval u/s 80G of the Income Tax Act, 1961 (in short “The Act”).

2.

The assessee has raised the following grounds of appeal:-

ITA No.2503/Bang/2025 Nagarahole Tiger Conservation Foundation, Mysuru Page 2 of 3

3.

Before us both the parties fairly conceded that the assessee could not represent its case before the ld. CIT(Exemptions). We also agree with the contention of ld. CIT(Exemptions) that the assessee is mandated to submit the necessary documents to prove the genuineness of the activities of the Trust or institution and fulfillment of all the conditions laid down in clauses (i) to (v) of section 80G of the Act. In the present case, as the assessee could not responded to any of the notices and failed to appear before the ld. CIT(Exemptions) and submit the necessary details/documents as called for, the ld. CIT(Exemptions) rejected the Form No.10AB dated 19.3.2025 filed for approval u/s 80G of the Act and cancelled the approval.

4.

Before us, the ld. A.R. of the assessee vehemently submitted that one more opportunity may be granted before the ld.

ITA No.2503/Bang/2025 Nagarahole Tiger Conservation Foundation, Mysuru Page 3 of 3 CIT(Exemptions) in the interest of justice and fair play and also undertakes to appear and produce all the necessary documents/records before the ld. CIT(Exemptions). This being so, considering the fact that the society is established by the state Government under the provisions of wildlife (Protection) Act, 1972 for conservation of tigers and biodiversity as well as in the interest of justice, equity and fair play, we deem it fit and proper to remit the entire issue in dispute to the file of ld. CIT(Exemptions) to decide afresh in accordance with law. Needless to say, a reasonable opportunity of being heard must be granted to the assessee. The assessee is also directed to produce all the relevant documents/details/evidences/accounts/reports to substantiate its claim. We make it clear that in case of further default, the assessee shall not be entitled for any leniency. It is ordered accordingly.

5.

In the result, appeal filed by the assessee is partly allowed for statistical purposes.

Order pronounced in the open court on 27th Apr, 2026

Sd/- Sd/- (Prashant Maharishi) (Keshav Dubey) Vice President Judicial Member

Bangalore, Dated 27th Apr,2026. VG/SPS

Copy to: 1. The Applicant 2. The Respondent 3. The CIT 4. The DR, ITAT, Bangalore. 5 Guard file By order

Asst. Registrar, ITAT, Bangalore.

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