JAI SHRI RAM ANATH GAUSHALA SAMITI, TARANAGAR,TARANAGAR vs. CIT EXEMPTION, JAIPUR, CIT EXEMPTION, JAIPUR

ITA 1027/JODH/2025Status: DisposedITAT Jodhpur31 August 2026AY 2025-2610 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the mere filing of Form ITR-7 does not conclusively prove that exemption under Sections 11 and 12 was availed. The actual exclusion of income from total income is the decisive factor, which requires examination of the returns and related documents.

What were the facts?

The assessee applied for registration under Section 12A of the Income Tax Act. The CIT(Exemptions) rejected the application, holding that the assessee had availed exemption under Sections 11 and 12 by filing returns in Form ITR-7.

What were the issues?

Whether filing of ITR-7 by itself amounts to availing exemption under Sections 11 and 12. Whether the rejection of a 12A registration application based solely on the filing of ITR-7 is sustainable.

Which sections of the Income-tax Act were involved?

Section 12A,Section 12AB,Section 11,Section 12,Section 10(23C)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH JODHPUR

For Appellant: Shri Rajesh Bhagsinghka, CA
For Respondent: Ms. Shivani Bansal, CIT-DR (Physically)
Hearing: 06.08.2026Pronounced: 31.08.2026

PER MAKARAND VASANT MAHADEOKAR, AM:

This appeal by the assessee is directed against the order dated 27.09.2025 passed by the learned Commissioner of Income Tax (Exemptions), Jaipur [“CIT(E)”] in Form No. 10AD, in proceedings under section 12AB(1)(b)(ii) of the Income-tax Act,

2 Jai Shri Ram Anath Gaushala Samiti, Taranagar

1961 [“the Act”], whereby the application dated 28.02.2025 filed by the assessee in Form No. 10ABfor registration under section 12A of the Act was rejected.

2.

The assessee has raised the following grounds of appeal, which are reproduced verbatim:

1.

On the fa

The order continues below.

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