SOMDUTT DEEDWANIA CHARITABLE SANSTHAN, BHILWARA,JODHPUR vs. CIT EXEMPTION, JAIPUR, JAIPUR

ITA 700/JPR/2026Status: DisposedITAT Jaipur30 September 2026AY 2026-273 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal noted that the learned Authorised Representative (AR) for the assessee submitted that the assessee wished to withdraw the appeal before the Bench. Considering this submission, the Tribunal dismissed the appeal as withdrawn. Therefore, the Tribunal did not adjudicate on the merits of the grounds raised by the assessee regarding the rejection of the registration application by the learned CIT(E). The specific findings or reasoning on the issues of incompleteness of the application or the registration under the Rajasthan Public Trusts Act, 1959, were not reached due to the withdrawal. The operative direction was to dismiss the appeal.

What were the facts?

The assessee, Somdutt Deedwania Charitable Sansthan, filed an appeal against the order of the Commissioner of Income Tax (Exemption), Jaipur, dated 13.02.2026. This order rejected the assessee's application for registration under section 12AB of the Income Tax Act, 1961, filed in Form No. 10AB on 27.09.2025. The rejection was based on two grounds: the application was incomplete as a copy of registration under section 12A(1)(ac)(i) or (iii) was not provided, and the assessee was not registered under the Rajasthan Public Trusts Act, 1959, with no reply furnished on this issue. The assessee contended that it holds registration under section 80G and had submitted the Rajasthan Public Trusts Act registration certificate.

What were the issues?

1. Whether the learned CIT(E) erred in rejecting the application for registration under section 12AB of the Act on the grounds of incompleteness, specifically the absence of a copy of registration under section 12A(1)(ac)(i) or (iii), when the assessee claims to have fulfilled all conditions? 2. Whether the learned CIT(E) erred in holding that the assessee trust is unregistered under the Rajasthan Public Trusts Act, 1959, contrary to the material on record, as the assessee claims to have submitted the registration certificate? Assessee's contentions: The assessee argued that the order of the learned CIT(E) was bad in law and facts, with arbitrary and contradictory findings. It claimed to hold registration under section 80G and that the Rajasthan Public Trusts Act, 1959 registration certificate was duly submitted. The assessee asserted that it fulfilled all conditions for registration under section 12AB and that the CIT(E) failed to appreciate the charitable objects and genuineness of activities. The assessee also sought permission to raise additional grounds. Revenue's contentions: No specific contentions for the revenue were recorded in the judgment.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 12A(1)(ac)(ii),Section 12A(1)(ac)(i),Section 12A(1)(ac)(iii),Section 80G

AI-generated summary — verify with the full judgment below

IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, JAIPUR Before: Shri Kuldip Singh, Judicial Member And Shri Prakash, Accountant Member ITA No: 700/JPR/2026 Assessment Year: 2026-27 PAN: AAPTS 7928A (Appellant) Assessee Represented: Ms. Raksha Birla, CA (thru V.C.) Revenue Represented: Sh. Shravan Kumar Meena, CIT Date of hearing : 23-09-2026 Date of pronouncement : 30-09-2026

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 13.02.2026 passed in Form No. 10AD under section 12AB(1)(b)(ii) of the Income Tax Act, 1961 (hereinafter referred to as "the Act"), rejecting the application of the Assessee for registration under section 12AB of the Act.

2.

The grounds of appeal raised by the Assessee before us read as under:

"1] That on the facts and in the circumstances of the case, the order passed by ld CIT(Exemption) is bad in law and bad in facts.

2] That on the facts and in the

The order continues below.

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