SHIROMANI SANT BABA BALWANT SG MATA RANJIT KAUR MEM CHARITABLE TRUST,TANDA vs. INCOME TAX OFFICER -WARD(EXEMPTION), JALANDHAR

ITA 927/ASR/2026Status: DisposedITAT Amritsar29 September 2026AY 2027-20285 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the order of the learned CIT(E) rejecting the assessee's applications for registration under Section 12AB and approval under Section 80G should be set aside. The Tribunal found that the CIT(E)'s approach of changing the assessee's status to a religious entity was not based on cogent material, but solely on an inadvertent error in filing Form 10AB. The assessee's claim that its activities are exclusively charitable, particularly in running medical relief services through Baba Balwant Singh Ji Memorial Charitable Hospital, was corroborated by its previous registrations as a charitable trust. The Tribunal noted that the assessee had reported 'NIL' expenditure on religious activities in the relevant Form 10AB. Since the appeal against the rejection of the Section 80G approval is consequential to the outcome of the Section 12AB registration, it would meet the same fate. Therefore, the Tribunal directed the CIT(E) to grant the registration and approval sought by the assessee for both applications.

What were the facts?

The assessee, Shiromani Sant Baba Balwant SG Mata Ranjit Kaur Mem Charitable Trust, filed an appeal against the order of the learned CIT(E), Chandigarh, dated 20.01.2026. This order rejected the assessee's applications for registration under Section 12A(1)(b) and approval under Section 80G of the Income-tax Act, 1961. The appeals were filed belatedly by 125 days, and the Tribunal condoned the delay. The primary reason for rejection by the CIT(E) was that Form 10AB described the nature of activities as 'religious cum charitable,' leading the CIT(E) to classify the assessee as a 'Religious Entity'. The assessee argued this was a clerical error in Form 10AB, and its actual activities are exclusively charitable, focusing on medical relief. The assessee had previously held registration under Section 12A and approval under Section 80G as a charitable trust.

What were the issues?

1. Whether the assessee's application for registration under Section 12AB of the Income-tax Act, 1961, should be rejected on the grounds that Form 10AB described its activities as 'religious cum charitable', thereby classifying it as a 'Religious Entity' by the CIT(E)? Assessee's Contentions: - The description 'religious cum charitable' in Form 10AB was a clerical error; the assessee's actual activities are exclusively charitable, primarily providing medical relief. - The assessee has a history of being registered as a charitable trust under Section 12A and approved under Section 80G since 2006 and 2007, respectively. - No religious ceremonies or expenditures on religious worship have been undertaken by the assessee. - The audited financial details support its charitable and educational activities. Revenue's Contentions: The judgment does not record specific contentions made by the revenue. However, the CIT(E)'s order, which is under challenge, rejected the application based on the 'religious cum charitable' description in Form 10AB.

Which sections of the Income-tax Act were involved?

Section 12A(1)(b),Section 80G,Section 12AB,Section 12A(1)(ac)(i)

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: 29.09.2026

PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

This appeal is filed by the assessee against the order of the ld. CIT (E), Chandigarh, dated 20.01.2026, rejecting the application seeking registration u/s 12A(1)(b) and approval u/s 80G of the Income-tax Act, 1961 (henceforth the Act).

2.

It is pointed out that the appeals are filed belatedly with 125 days. Assessee filed petition for condonation of delay along with an affidavit before the Tribunal which is placed on record. Explanation furnished by the assessee in respect of the I.T.A. No.959 and 927/Asr/2026 Shiromani St. Baba Balwant SG Mata Ranjit Kaur Mem Charitable Trust 2

The order continues below.

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