SATGURU RAM SINGH SATSANG CHARITABLE SOCIETY,,MOGA vs. COMMISSIONER OF INCOME TAX (T EXEMPTIONS ), CHANDIGARH

ITA 919/ASR/2026Status: DisposedITAT Amritsar29 September 2026AY 2026-20275 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(E)'s conclusion that the assessee is a religious entity was based solely on an inadvertent error in filing Form 10AB, which described the activities as 'religious cum charitable'. The Tribunal found that the assessee's actual conduct of activities, as supported by audited financial details demonstrating the running of an educational institution, clearly indicated charitable and educational activities. Furthermore, the Tribunal noted a violation of the principles of natural justice, as no notice was issued to the assessee, nor was it given an opportunity to explain its case before its status was changed. The Tribunal observed that the assessee had previously been granted registration under section 12A and approval under section 80G as a charitable trust. The appeal against the rejection of the section 80G approval was consequential to the outcome of the section 12AB registration. Therefore, the Tribunal set aside the order of the CIT(E) and directed him to grant the registration sought by the assessee under section 12AB and the approval under section 80G. The ratio decidendi is that an inadvertent clerical error in a form, if demonstrably contradicted by actual activities and financial records, should not lead to the rejection of registration or approval, especially when principles of natural justice are violated.

What were the facts?

The assessee, Satguru Ram Singh Satsang, filed appeals against the order of the CIT(E), Chandigarh, dated 17.02.2026, which rejected its applications for registration under section 12AB(1)(b) and approval under section 80G of the Income-tax Act, 1961, for Assessment Year 2026-27. The appeals were filed belatedly by 79 days, and the delay was condoned by the Tribunal. The CIT(E) rejected the applications primarily because Form 10AB described the assessee's activities as 'religious cum charitable' and 'religious' was listed as an object, leading the CIT(E) to classify the assessee as a 'Religious Entity'. The assessee contended that it is a charitable society established in 2004, primarily running a CBSE-affiliated school up to Class 12th. It previously held registration under section 12A since 03.09.2007 and approval under section 80G since 24.04.2008 as a charitable entity. The assessee argued that the 'religious cum charitable' description in Form 10AB was a clerical error, and its actual activities, supported by audited financial statements, are educational and charitable.

What were the issues?

1. Whether the assessee's application for registration under section 12AB(1)(b) of the Income-tax Act, 1961, was rightly rejected by the CIT(E) on the ground that it is a 'Religious Entity' based on the description in Form 10AB. 2. Whether the assessee's application for approval under section 80G of the Income-tax Act, 1961, was rightly rejected by the CIT(E) as a consequence of the rejection of the section 12AB application. Assessee's Contentions: - The description 'religious cum charitable' in Form 10AB was a clerical error; the assessee's actual activities are purely charitable, focused on running an educational institution as evidenced by its audited financial statements. - The CIT(E) erred in classifying the assessee as a religious entity without identifying any religious ceremonies, expenditures on religious worship, or propagation of any particular faith. - There was a gross violation of the principles of natural justice as no notice was issued to the assessee, nor was it given an opportunity to explain its case before its status was re-characterized. Revenue's Contentions: The judgment records no specific contentions for the revenue.

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, AMRITSAR BENCH, AMRITSAR.

Before: SH. SAKTIJIT DEY, HON’BLE & SH. GIRISH AGRAWAL, HON’BLE

Hearing: 29.09.2026Pronounced: 29.09.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

These two appeals are filed by the assessee against the order of the ld. CIT (E), Chandigarh, dated 17.02.2026, rejecting the applications seeking registration u/s 12AB(1)(b) and approval u/s 80G of the Income-tax Act, 1961 (henceforth the Act).

2.

It is pointed out that the petition filed belatedly with 79 days the assessee filed a petition along with an affidavit in spite of the present appeal before the Tribunal

I.T.A. Nos. 919 and 920/Asr/2026 Satguru Ram Singh Satsang 2 Assessment Year: 2026-27 for the condonation of delay is placed on record. Explanation furnished by the assessee in respect of the de

The order continues below.

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