LAWRENCE AND MAYO EDUCATIONAL SOCIETY,AJMER vs. CIT EXEMPTION, JAIPUR, JAIPUR

ITA 926/JPR/2026Status: DisposedITAT Jaipur28 September 2026AY 2026-273 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal considered the rival submissions and the materials on record, including the registration application filed before the RPT authorities. In the interest of justice, the Tribunal set aside the impugned orders passed by the CIT(E). The Tribunal directed that the assessee trust be given one more opportunity of hearing and that the CIT(E) should pass orders in accordance with the provisions of law. The Tribunal did not make a finding on the merits of the denial of registration but allowed the appeals for statistical purposes to provide the assessee with an opportunity to rectify the deficiencies. The operative direction is to grant a fresh opportunity for hearing and decision.

What were the facts?

The assessee, Lawrence and Mayo Educational Society, filed two appeals (ITA Nos. 925 and 926/JPR/2026) against orders dated 28.03.2026 passed by the Commissioner of Income Tax (Exemption), Jaipur. These orders denied registration under Section 12AB of the Income Tax Act, 1961, and consequently under Section 80G. The denial was primarily due to non-registration under the Rajasthan Public Trust Act, 1959, and the filing of an incomplete Form 10AB. The assessment year in question is 2026-27. The assessee's counsel requested that the matter be set aside to the CIT(E) to allow the filing of all necessary details for registration.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) erred in denying registration under Section 12AB of the Income Tax Act, 1961, to the assessee for non-registration under the Rajasthan Public Trust Act, 1959, and for filing an incomplete Form 10AB? (Question of law and fact, turning on Section 12AB and Section 12A). 2. Whether the Commissioner of Income Tax (Exemption) erred in denying registration under Section 80G of the Income Tax Act, 1961, as a consequence of the denial under Section 12AB? (Question of law and fact, turning on Section 80G). Assessee's contention: The assessee's counsel argued that the trust had applied for registration under the RPT Act on 21st January 2026, and requested the matter be set aside to the CIT(E) to enable the filing of all necessary details for obtaining registration under Section 12AB and Section 80G(5). Revenue's contention: The CIT DR for the Revenue 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,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: 28.09.2026

Per T. R. Senthil Kumar, JM :-

These two appeals are filed by the assessee as against separate orders both dated 28.03.2026 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 for filing incomplete Form 10 AB and consequently denying registration u/s 80G of the Act.

2.

At the outset, Learned Counsel for the assessee submitted that the assessee trust applied for registration in Form No. 6 for registration Asst. Year: 2026-27 under RPT Act vide application dated 21st January 2026, and copy of the same produced before us. Thus, Ld.

The order continues below.

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