SHREE RAM MANDIR PRANAYAS SHREE SANATAN DHARAM SABHA,JAIPUR vs. CIT(E), JAIPUR, JAIPUR

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ITA 1284/JPR/2025Status: DisposedITAT Jaipur26 May 20263 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that assessees should not be punished for bona fide mistakes, especially given the confusion surrounding recent amendments. The CIT(E) was directed to consider the application on merits, treating it under the correct clause.

What were the facts?

The assessee applied for regular registration under Section 12A but inadvertently ticked the wrong clause in the application form. The CIT(E) rejected the application solely on this technical ground.

What were the issues?

Whether an application for registration under Section 12A can be rejected due to a bona fide error in mentioning the specific sub-clause, despite the assessee being otherwise eligible.

Which sections of the Income-tax Act were involved?

Section 12A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Hearing: 19.03.2026Pronounced: 26.05.2026

P a g e | 1 ITA No. 1284/JPR/2025 Shree Ram Mandir Pranayas Shree Sanatan Dharam Sabha IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES, “A” BENCH, JAIPUR BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER & SHRI RATNESH NANDAN SAHAY, ACCOUNTANT MEMBER ITA No. 1284/JPR/2025 (Assessment Year:NA) Shree Ram Mandir Vs. CIT(E), Pranayas Shree Sanatan Jaipur Dharam Sabha Shri Ram Mandir Adarsh Nagar, Adarsh Nagar, Jaipur �थायीलेखासं./जीआइआरसं./PAN/GIR No: AACTS2586D Appellant .. Respondent Appellant by : Sh. P. C. Parwal, CA Respondent by : Sh. Rajesh Ojha, CIT Date of Hearing 19.03.2026 Date of Pronouncement 26.05.2026 O R D E R Per Sanjay Garg, Judicial Member: The present appeal has been preferred by the assessee against the order of Ld. Commissioner of Income Tax (Exemptions), Jaipur (hereinafter referred to as “Ld. CIT(E)”) dated 13.08.2025rejecting the application of the assessee for registration u/s 12A of the Income Tax Act,1961 (hereinafter referred to as “the Act”).

P a g e | 2 ITA No. 1284/JPR/2025 Shree Ram Mandir Pranayas Shree Sanatan Dharam Sabha 2. In this case, the assessee applied for provisional registration u/s 12A(1)(ac)(vi)(A) of the Act, which was granted to the assessee-trust vide order of the Ld. CIT(E) dated 03.08.2022. The assessee, thereafter, applied for regular/final registration to the Ld. CIT(E). However, inadvertently mentioned/ticked the clause as 12A(1)(ac)(ii) instead of clause (iii) in the prescribed form. Merely, on this ground, the Ld. CIT(E) rejected the application of the assessee observing that his office suo moto cannot change the clause under which the application has to be made.

3.

It is observed here that after the amendment to the relevant provisions w.e.f. 01.04.2021, there were many misunderstandings and confusions about the correct interpretation of the same, not only among the assessees/Income Tax professionals, but also with the Income Tax Authorities. Even the CBDT had to issue circulars and clarifications regarding correct interpretation of the relevant provisions from time to time. Even the time/limitation for making the applications has also been extended from time to time taking note of such confusions in properly understanding relevant provisions. The Co-ordinate Benches of the Tribunal have held time and again that due to the complex provisions and even there being certain discrepancies in prescribed forms for issuing certificates, the assessees should not be punished for any mistake in mentioning the relevant clause in the application form. In the case in hand, the entire facts were before the Ld. CIT(E) and he was very much aware that the case of the assessee was otherwise eligible

P a g e | 3 ITA No. 1284/JPR/2025 Shree Ram Mandir Pranayas Shree Sanatan Dharam Sabha for granting final/regular registration, however, he found himself helpless only because the assessee had not mentioned correct clause. It has been held time and again that the litigants should not be punished for their bona fide mistakes. The impugned order of the Ld. CIT(E) is set aside and the matter is restored to the file of the CIT(E). It is directed that the Ld. CIT(E) will treat the application moved by the assessee under the relevant clauses 12A(1)(ac)(iii), irrespective of the clause mentioned by the assessee in the application form and will decide the application of the assessee afresh on merits in accordance with law.

4.

With the above observations, the appeal of the assessee is treated as allowed for statistical purposes. Order is pronounced under provision of Rule 34 of ITAT Rules, 1963 on 26/05/2026.

Sd/- Sd/- (Ratnesh Nandan Sahay) (Sanjay Garg) Accountant Member Judicial Member Dated 26.05.2026 Mittali, Sr. PS Copy forwarded to: 1. Appellant 2. Respondent 3. CIT 4. CIT(Appeals) 5. DR: ITAT By Order, Asst. Registrar ITAT, Jaipur

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