MAHAVIR DIGAMBAR JAIN PARMARTHIK SANSTHA ,SATNA vs. CIT(EXMPTION), BHOPAL

ITA 155/JAB/2023Status: DisposedITAT Jabalpur15 May 2026AY 2023-246 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) failed to provide the assessee with an opportunity to rebut the negative findings, particularly regarding the computation of religious expenditure. This procedural lapse violated the principles of natural justice.

What were the facts?

The assessee, a registered public trust, applied for regular registration under Section 80G after having provisional registration. The CIT(E) rejected the application, citing reasons including religious expenditure exceeding the cap and the trust's objects being confined to specific communities.

What were the issues?

Whether the rejection of the 80G registration application was justified without providing the assessee an opportunity to be heard on the adverse findings, especially concerning the computation of religious expenditure.

Which sections of the Income-tax Act were involved?

Section 80G(5),Section 80G(5B),Section 80G(2)(iv)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JABALPUR BENCH, MP

Before: HON’BLE SHRI KUL BHARAT & SHRI G.D. PADMAHSHALI

For Appellant: Mr Sapan Usrethe [‘Ld. AR’]
For Respondent: Mr N M Prasad [‘Ld. DR’]
Pronounced: 15/05/2026

PER G. D. PADMAHSHALI; The assessee filed present appeal impugning the DIN & Order No.

ITBA/EXM/F/EXM45/2023-24/1057456048(1) dt. 27/10/2023

passed u/s 80G(5) of the Income Tax Act, 1961 [‘the Act’] by the Commissioner of Income Tax (Exemption), Bhopal [‘Ld. CIT(E)’]

whereby application for grant of 80G registration was rejected.

ITAT-Jabalpur Mahavir Digamber Jain Parmarthik Sanstha Vs. CIT(E)

2.

We have heard the rival contentions of both parties; subject to provisions of rule 18 of Income Tax Appellate Rules, 1963 [‘ITAT Rules’ hereinafter] perused material placed on records.

3.

We note that; a. The assessee is a registered public trus

The order continues below.

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