PROF. DR. SOHAN RAJ- LAXMI DEVI, TATER CHERITABLE TRUST,JODHPUR vs. CIT (EXEMPTION), JAIPUR

ITA 1108/JODH/2025Status: DisposedITAT Jodhpur31 August 202614 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the CIT(E)'s conclusions regarding commerciality and religious activity were based on assumptions and required further factual verification. The rejection of the 80G application was also linked to the 12AB rejection.

What were the facts?

The assessee, a charitable trust, applied for registration under section 12AB and approval under section 80G. The CIT(E) rejected both applications, citing commercial activities like monetized YouTube channels and religious propagation as reasons for ineligibility.

What were the issues?

Whether the trust's activities, including video production and broadcasting, constitute charitable purposes under Section 2(15) and if they disqualify it from registration under Section 12AB and approval under Section 80G.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G,Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “DB” BENCH JODHPUR

Before: SHRI SAKTIJIT DEY & SHRI MAKARAND VASANT MAHADEOKAR

For Appellant: Shri Rajendra Jain, Adv. (Physically)
For Respondent: Ms. Shivani Bansal, CIT-DR (Physically)
Hearing: 06.08.2026Pronounced: 31.08.2026

PER MAKARAND VASANT MAHADEOKAR, AM: These two appeals filed by the assessee, Prof. Dr. Sohan Raj-Laxmi Devi, Tater Charitable Trust, Jodhpur, arise from two separate orders dated 14.11.2025 passed by the learned Commissioner of Income Tax (Exemption), Jaipur [hereinafter referred to as "the CIT(E)"]. Since both appeals pertain to the Prof. Dr. Sohan Raj – Laxmi Devi, Tater Cheritable Trust same assessee, arise from the same set of facts and involve interconnected issues concerning registration under section 12AB and approval under section 80G(5) of the Income

The order continues below.

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