HEAVENLY LADDER MINISTRIES,THIRUVALLUR vs. COMMISSIONER OF INCOME TAX EXEMPTION, CHENNAI

ITA 2883/CHNY/2026Status: DisposedITAT Chennai23 September 2026AY 2027-283 pages
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What did the Tribunal hold?

The Tribunal held that the Commissioner of Income Tax (Exemption) was not justified in rejecting the assessee's application for registration under Section 80G(5) of the Income Tax Act solely on the ground that the assessee's name contained the expression 'religious'. The Tribunal noted that it has consistently held that the expression 'religious' in the name of a trust does not automatically absolve it from seeking registration under Section 80G(5). Crucially, the CIT(E) failed to examine the objects of the trust, which is a necessary step in determining the approval under Section 80G(5). The reasoning of the CIT(E) in paragraph 4.3 of the impugned order was found to be unjustified. Therefore, the order of the CIT(E) was set aside. The Tribunal directed the CIT(E) to reconsider the application for registration under Section 80G(5) after providing a reasonable opportunity to the assessee to present their case. The grounds raised by the assessee were allowed for statistical purposes.

What were the facts?

The assessee, Heavenly Ladder Ministries, filed an appeal against the order dated 17.03.2026 passed by the Commissioner of Income Tax (Exemption), Chennai, for the assessment year 2027-28. The appeal was filed challenging the rejection of the assessee's application for registration under Section 80G(5) of the Income Tax Act. The assessee was represented by no one, and no adjournment was sought. The revenue was represented by the learned DR. The CIT(E) had rejected the application solely on the ground that the assessee's name, 'Heavenly Ladder Ministries', contained the expression 'religious', which was deemed inappropriate for a registered religious cum charitable trust. The tribunal noted that the CIT(E) did not discuss the objects of the trust in its decision.

What were the issues?

1. Whether the Commissioner of Income Tax (Exemption) was justified in rejecting the assessee's application for registration under Section 80G(5) of the Income Tax Act, 1961, solely on the ground that the assessee's name contained the expression 'religious'. (Question of law) Assessee's Contentions: The assessee did not appear before the Tribunal, and therefore, no contentions were recorded on their behalf. However, the Tribunal's reasoning implies that the assessee would likely argue that the presence of 'religious' in the name should not be a sole ground for rejection and that the objects of the trust should have been examined. Revenue's Contentions: The revenue, represented by the learned DR, did not present any specific arguments recorded in the judgment. However, the CIT(E)'s order, which is under challenge, rejected the application.

Which sections of the Income-tax Act were involved?

Section 80G(5)

AI-generated summary — verify with the full judgment below

Before: SHRI. INTURI RAMA RAO & BEFORE SHRI S.S. VISWANETHRA RAVI

Hearing: 09.09.2026

PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 17.03.2026 passed by the Commissioner of Income Tax (E), Chennai, for the assessment year 2027-28

2.

We find no representation on behalf of assessee nor filed any application seeking adjournment. The assessee called absent and we proceed to hear the Ld. DR and passed order considering the material available on record.

3.

At the outset it is noted tha

The order continues below.

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