SHREE VALLABH DHAM CHARITABLE TRUST,DELHI vs. CIT(EXEMPTION), DELHI

ITA 2515/DEL/2026Status: DisposedITAT Delhi23 September 2026AY 2024-259 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the CIT(E) rejected the application for registration and approval due to the absence of donor confirmations, evidence of charitable activities (photographs/bills), details of beneficiaries, details of recipient trusts, and particulars relating to 'Social Activities' expenditure. The Tribunal found that the applicant needed one more effective opportunity to submit these documents. Therefore, the impugned orders of the CIT(E) were set aside, and the matter was restored to the file of the CIT(E) for deciding afresh. The assessee was directed to make necessary detailed submissions before the CIT(E). The Tribunal allowed the appeals for statistical purposes.

What were the facts?

The assessee, Shree Vallabh Dham Charitable Trust, filed appeals against the order of the CIT(Exemptions), Delhi, dated 29.11.2024. The CIT(E) rejected the trust's application for registration under Section 12A(1)(ac)(iii) and approval under Section 80G of the Income Tax Act, 1961. The rejection was based on the absence of registration under Section 12AB. The assessee sought condonation of a 403-day delay in filing the appeals, which the Tribunal granted. The appeals were for Assessment Year 2024-25. The CIT(E)'s order noted discrepancies including lack of donor confirmations, evidence of charitable activities, beneficiary details, and particulars of recipient trusts for donations made by the assessee.

What were the issues?

1. Whether the learned CIT(Exemptions) erred in rejecting the application for registration under Section 12A(1)(ac)(iii) / 12AB of the Income-tax Act, 1961, without properly appreciating the documents and conducting a fair examination of the material submitted, and whether the rejection was bad in law due to alleged non-compliance and violation of principles of natural justice. 2. Whether the learned CIT(Exemptions) erred in rejecting the application for approval under Section 80G(5)(iii) of the Income-tax Act, 1961, on similar grounds as the Section 12A application, including alleged non-furnishing of requisite information and violation of natural justice. Assessee's Contentions: The assessee argued that the CIT(E) rejected the applications without issuing a prior show cause notice, violating principles of natural justice. They contended that all relevant documents were filed and the activities were genuine. The assessee requested one more opportunity to present its case and furnish documents. Revenue's Contentions: The revenue argued that the CIT(E) rightly rejected the applications because the assessee failed to satisfy the genuineness of its activities.

Which sections of the Income-tax Act were involved?

Section 12A(1)(ac)(iii),Section 12AB,Section 80G(5)(iii),Section 2(15)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI BENCH ‘C’, NEW DELHI

Before: Sh. Raj Kumar Chauhan&

Hearing: 09.09.2026Pronounced: 23.09.2026

Heard together (2 matters)

ITA No. 2515/Del/2026
ITA No. 2516/Del/2026

Read from the judgment's own cause title. This page is filed under one of them.

Per Raj Kumar Chauhan, Judicial Member:

The appeals are directed against the order of the Ld. CIT(E), Delhi, dated 29.11.2024, wherein the application for registration u/s 12A(1)(ac)(iii) of the Act, filed by the applicant on 31.05.2024 in ITA Nos. 2515 & 2516/Del/2026, respectively alongwith request to the approval u/s 80G of the Act has been rejected in the absence of registration u/s 12AB of the Act.

2.

The assessee has filed an affidavit seeking condonation of delay of 403 days in filing both appeals. The contents of the affidavit are reproduced as under: ITA Nos. 2515 & 2516/Del/2

The order continues below.

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