MATA GURMAIL KAUR CHARITABLE TRUST,LUDHIANA vs. CIT EXEMPTIONS CHANDIGARH, CHANDIGARH

ITA 27/ASR/2026Status: DisposedITAT Amritsar31 August 2026AY 2026-275 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT erred in rejecting the registration application solely on the ground of no activities in the preceding three years. The focus at the registration stage should be on the objects of the trust and a prima facie satisfaction of genuineness, not the quantum of past activities.

What were the facts?

The assessee, Mata Gurmail Kaur Charitable Trust, applied for registration under Section 12A(1)(ac)(ii) of the Income Tax Act. The CIT (Exemption) rejected the application, citing that no charitable activities were carried out in the preceding three years.

What were the issues?

Whether denial of registration under Section 12AB is justified solely due to absence of charitable activities in preceding years. Whether the CIT correctly applied the provisions of Sections 11 and 12 at the stage of registration.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 12AB,Section 11,Section 12

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, AMRITSAR BENCH, AMRITSAR.

Before: SH. S. RIFAUR RAHMAN & SH. UDAYAN DAS GUPTA

For Appellant: CA & Sh
Hearing: 22.07.2026Pronounced: 31.08.2026

Per: Udayan Dasgupta, JM: This appeal is filed by the assessee against the order of the Ld CIT (E), Chandigarh, dated 19/11/2025, rejecting the application for registration dated 26/08/2025, filed by the assessee in Form 10AB, u/s 12A(1)(ac)(ii) of the Income Tax Act 1961( henceforth the Act ).

2.

The grounds of appeal taken by the assessee in the memorandum of appeal in form 36 are as follows:

“1. That the impugned order passed by the Ld. CIT (Exemptions), Chandigarh rejecting the application for registration under section 12A(1)(ac)(ii)/12AB of the Income-tax Act, 1961 is illegal, arbitrary, unjustified and bad in law.

The order continues below.

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