MAHAVIR INTER NATIONAL CO,RAJASTHAN vs. EXEMPTION WARD 1, JAIPUR, JAIPUR

ITA 971/JPR/2026Status: DisposedITAT Jaipur30 September 2026AY 2025-264 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the rejection of the assessee's application for registration under Section 12A was justified. The primary reason for rejection was the assessee's failure to be registered under the Rajasthan Public Trust Act, 1959, which is a prerequisite for registration under Section 12A. Additionally, the Tribunal noted the incomplete application form (Form 10AB) and the non-furnishing of mandatory documents, including copies of existing registrations and the instrument of creation or establishment. Consequently, since the 12A registration was denied, the approval under Section 80G, which is contingent upon 12A registration, was also rightly denied. The Tribunal found no reason to interfere with the orders of the CIT(E). The operative direction was to uphold the orders of the CIT(E), meaning the appeals were dismissed.

What were the facts?

The assessee, Mahavir International CO, filed two appeals (ITA Nos. 966 and 971/JPR/2026) before the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, against orders passed by the Commissioner of Income Tax (Exemption), Jaipur (CIT(E)). The appeals concern the rejection of the assessee's applications for approval under Section 80G and registration under Section 12A of the Income Tax Act, 1961. The CIT(E) denied 80G approval due to the absence of 12A registration. The 12A registration was rejected because the assessee was not registered under the Rajasthan Public Trust Act, 1959, and due to incomplete Form 10AB and alleged non-genuineness of activities. Specific missing documents for the 12A application included copies of existing 12A(1)(ac) and 80G(5) registrations (for renewal), and the instrument or document evidencing the creation or establishment of the applicant.

What were the issues?

1. Whether the rejection of the assessee's application for registration under Section 12A of the Income Tax Act, 1961, by the CIT(E) was justified, considering the grounds of non-registration under the Rajasthan Public Trust Act, 1959, incomplete Form 10AB, and non-genuineness of activities. 2. Whether the denial of approval under Section 80G of the Income Tax Act, 1961, by the CIT(E) was justified, given that it was contingent on the 12A registration. Assessee's contentions: The assessee did not present any arguments as they were represented by 'None' at the hearing. Revenue's contentions: The revenue, represented by Sh. Anil Dhaka, CIT, likely supported the orders of the CIT(E) by highlighting the deficiencies in the assessee's application and the reasons for rejection as recorded by the CIT(E). The judgment does not explicitly detail the revenue's arguments beyond the CIT(E)'s order.

Which sections of the Income-tax Act were involved?

Section 80G,Section 12A

AI-generated summary — verify with the full judgment below

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

Before: SMT. ANNAPURNA GUPTA & SHRI T. R. SENTHIL KUMAR

Hearing: 23.09.2026Pronounced: 30.09.2026

Per Annapurna Gupta, AM:- Both the present appeals have been filed by the assessee against the separate orders passed by the CIT Exemption Jaipur (hereinafter referred to as “Ld. CIT(E)”), both dated 19.03.2026 for rejecting assessee’s application seeking approval under Section 80G of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) and registration under Section 12A of the Act.

P a g e | 2 ITA Nos.966 and 971/JPR/2026 Mahavir International CO

2.

Approval u/s 80G of the Act has been denied on account of absence of registration u/s 12A of the Act. Since the issues involved in the appeals are interlinked, both the appeals were taken up for hearing together and are being disposed o

The order continues below.

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