GURKARTAR DHARAM ARTH TRUST NARANGWAL,LUDHIANA vs. CIT EXEMPTIONS CHANDIGARH, CHANDIGARH

ITA 33/ASR/2026Status: DisposedITAT Amritsar31 August 2026AY 2025-266 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that at the registration stage, the genuineness of the trust's objects and proposed activities should be examined, not just past activities. The CIT's rejection based solely on the absence of current activities was incorrect.

What were the facts?

The assessee trust applied for registration under Section 12A(1)(ac)(ii) of the Income Tax Act. The CIT (Exemption) rejected the application, citing the absence of actual charitable activities and lack of evidence for their genuineness. The trust had prior registrations and its objects were charitable.

What were the issues?

Whether the absence of actual charitable activities is a valid ground for rejecting a trust's application for registration under Section 12AB, and whether proposed activities should be considered.

Which sections of the Income-tax Act were involved?

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

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 10/11/2025, 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 2 Assessment Year: 2025-26

section 12A(1)(ac)(ii)/12AB of the Income-tax Act, 1961 is ille

The order continues below.

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