FARMER (FOURM OF AGRIULTURIST AND RURAL MEGAMIND ENABLERS RAJA) ,JAIPUR vs. CIT EXEMPTION JAIPUR, JAIPUR

ITA 284/JPR/2026Status: DisposedITAT Jaipur28 September 20263 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal, considering the rival submissions and the materials on record, including the registration application filed before the RPT authorities, decided in the interest of justice to set aside the impugned orders passed by the CIT(E). The Tribunal directed that the assessee trust be given one more opportunity of hearing. The CIT(E) is to pass orders in accordance with the provisions of law after considering the fresh submissions and documents. The ratio of this decision is that procedural fairness and an opportunity to rectify omissions are paramount, especially when a party demonstrates a willingness to comply and has initiated the necessary steps. The operative direction is to remand the matter back to the CIT(E) for fresh adjudication.

What were the facts?

The assessee, a trust, filed two appeals before the Income Tax Appellate Tribunal (ITAT), Jaipur Bench, challenging orders dated 30.01.2026 passed by the Commissioner of Income Tax (Exemption), Jaipur. The CIT(E) had denied registration under Section 12AB of the Income Tax Act, 1961, citing non-registration under the Rajasthan Public Trust Act, 1959, and also denied registration under Section 80G of the Act due to incomplete Form 10AB. The assessment years are not specified (NA). The assessee's counsel requested the matter be set aside to allow the filing of necessary details before the CIT(E) for grant of registration. The Revenue's counsel had no objection to this approach, provided the assessee furnished all required materials.

What were the issues?

1. Whether the impugned orders denying registration under Section 12AB and Section 80G of the Income Tax Act, 1961, are sustainable in law, considering the assessee's submission that it applied for registration under the Rajasthan Public Trust Act, 1959, and sought an opportunity to file complete details for the Income Tax registrations. Assessee's Contention: The assessee argued that it had applied for registration under the Rajasthan Public Trust Act, 1959, on 23rd September 2026, and sought to set aside the matter to the CIT(E) to provide all necessary details for obtaining registration under Section 12AB and Section 80G(5) of the Act. Revenue's Contention: The Revenue's counsel had no objection to setting aside the matter, but insisted on the production of all relevant materials, details, and evidence by the assessee for granting registration.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 80G

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: 28.09.2026

Per T. R. Senthil Kumar, JM :-

These two appeals are filed by the assessee as against separate orders both dated 30.01.2026 passed by Commissioner of Income Tax (Exemption), Jaipur denying registration under section 12 AB of the Income Tax Act, 1961 for non-registration under Rajasthan Public Trust Act, 1959 and also filing incomplete Form 10 AB and consequently denying registration u/s 80G of the Act. Asst. Years: NA

2.

At the outset, Learned Counsel for the assessee submitted that the assessee trust applied for registration in Form No. 6 for registration under RPT Act vide application dated 23

The order continues below.

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