SHRI SHRI 108 SHRI MAHARAJ HARIDAS PRANYAS,JAIPUR vs. CIT EXEMPTION, JAIPUR, JAIPUR

ITA 1042/JPR/2026Status: DisposedITAT Jaipur30 September 2026AY 2026-277 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the impugned order rested on a single ground: the application was incomplete for want of the certificate of registration under section 12AA of the Act held before 01.04.2021. No adverse findings were recorded on other essential aspects required under section 12AB(1)(b). The Tribunal admitted additional evidence, including an affidavit and an order under section 154, which supported the assessee's claim of prior 12AA registration. The Tribunal noted that the absence of the original certificate with the assessee cannot be conclusive if departmental records confirm the registration. Following its own coordinate bench decisions in Bai HirabaiManchersha Gilder Charity Trust and Shri Ramkrishna AyurvedikAushdahalayaParmarthi Trust, the Tribunal set aside the impugned order. The application was restored to the file of the CIT(E) with a direction to verify the prior 12AA registration from departmental records. If confirmed, the application should not be treated as incomplete. The CIT(E) was then directed to examine the application on merits as per section 12AB(1)(b). The grounds of appeal were allowed for statistical purposes.

What were the facts?

The assessee, Shri Shri 108 Shri Maharaj Haridas Pranyas, filed an appeal against the order of the Commissioner of Income Tax (Exemption), Jaipur (CIT(E)), dated 19.03.2026. The CIT(E) rejected the assessee's application filed in Form No. 10AB for registration under section 12A(1)(ac)(ii) of the Income Tax Act, 1961, for assessment year 2027-28 onwards. The rejection was based on the application being incomplete due to the non-submission of the prior 12AA registration certificate. The assessee, a religious cum charitable trust, had previously obtained registration under section 12A(1)(ac)(i) in Form No. 10AC and approval under section 80G for assessment years 2022-23 to 2026-27. The assessee contended that the 12AA certificate was lost and requested the CIT(E) to verify from departmental records, providing an 80G certificate and an order under section 154 which mentioned its 12AA registration.

What were the issues?

1. Whether the learned CIT(E) erred in law and on facts in rejecting the application under section 12A(1)(ac)(ii) for renewal of registration under section 12A, solely on the ground of non-production of the prior 12AA registration certificate. Assessee's contentions: The application was rejected for failing to submit a certificate issued over four decades ago, which was not traceable in its records. The departmental records and an order under section 154 of the Act confirm the prior registration. The assessee relied on the decisions in Shri Ramkrishna AyurvedikAushdahalayaParmarthi Trust v. CIT (Exemption) and Bai HirabaiManchersha Gilder Charity Trust v. CIT (Exemption). Revenue's contentions: The learned Departmental Representative relied on the order of the learned CIT(E) and opposed the relief sought.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(ii),Section 12A(1)(ac)(i),Section 80G(5),Section 12AB(4),Section 12AB(1)(b),Section 154,Section 143(1),Section 11,Section 12,Section 12A,Section 12AA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri Kuldip Singh & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Commissioner of Income Tax (Exemption), Jaipur [hereinafter referred to as "the learned CIT(E)"] dated 19.03.2026 passed in Form No. 10AD under section 12AB of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), rejecting the application of the Assessee filed in Form No. 10AB under section 12A(1)(ac)(ii) of the Act.

2.

The grounds of appeal raised by the Assessee before us in the memorandum of appeal in Form No. 36 read as under:

1.

The ld CIT(E) erred in law and on facts in rejecting t

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 12A(1)(ac)(ii)

All 679 judgments and leading authorities on Section 12A(1)(ac)(ii) →

Recent GST High Court judgments

Search GST case law →