SRI VRINDAVANA GOKULA CHARITABLE TRUST,BENGALURU vs. CIT (EXEMPTIONS), BENGALURU

ITA 1554/BANG/2026Status: DisposedITAT Bangalore24 September 2026AY 2026-2715 pages
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What did the Tribunal hold?

The Tribunal held that it has the power to condone the delay in filing the application for approval under Section 80G(5) of the Act, specifically Form No. 10AB. The Tribunal found that the delay in filing the application was procedural and that the assessee had demonstrated a reasonable and bonafide cause for the delay, stemming from confusion regarding the expiry dates of its various approvals. The Tribunal emphasized that procedural lapses should not defeat the substantive rights of charitable trusts. Relying on the coordinate bench decision in Vananchal Kelavani Trust and the Hon'ble Delhi High Court judgment in DCIT (Exemption) vs. Vishwa Jagriti Mission, the Tribunal condoned the delay. The matter was remitted back to the CIT (Exemptions) to decide the application on its merits, with a direction to grant a reasonable opportunity of being heard to the assessee. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Sri Vrindavana Gokula Charitable Trust, filed an appeal against the order of the CIT (Exemptions), Bangalore, dated 24.03.2026, which rejected its application for approval under Section 80G of the Income Tax Act, 1961. The rejection was based on the ground that the application in Form No. 10AB, filed on 16.09.2025, was delayed, as it should have been filed by 30.09.2024. The assessee argued that the delay was due to bonafide confusion between the expiry dates of its Section 80G approval and Section 12A registration. The trust had previously obtained approval under Section 80G(5)(vi) on 24.01.2020, and later a provisional approval under Section 80G(5) from 19.01.2023 to A.Y. 2025-26. The revenue contended that the Act does not permit condonation of delay for such applications.

What were the issues?

1. Whether the Tribunal has the power to condone the delay in filing an application for approval under Section 80G(5) of the Income Tax Act, 1961, specifically Form No. 10AB. The assessee contended that the delay in filing the application for renewal under Section 80G was due to bonafide confusion regarding the expiry dates of its existing Section 80G approval and Section 12A registration. The assessee argued that the delay was unintentional and arose from an honest belief that the Section 80G approval aligned with its Section 12AB registration. The assessee submitted that procedural lapses should not defeat substantive rights of charitable trusts seeking exemptions. The revenue relied on the order of the CIT (Exemptions) and argued that the assessee was callous in filing the application and that the provisions of the Act do not permit condonation of delay in filing an application for approval under Section 80G. The revenue prayed for the dismissal of the appeal.

Which sections of the Income-tax Act were involved?

Section 80G,Section 12A,Section 12AB,Section 80G(5),Section 80G(5)(vi),Section 10AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B’’BENCH: BANGALORE

Before: SHRI BALAKRISHNAN S. & SHRI KESHAV DUBEY

For Appellant: CA Akshaya K. S, A.R
Hearing: 06.07.2026Pronounced: 24.09.2026

PER KESHAV DUBEY, JUDICIAL MEMBER:

This appeal at the instance of the assessee is directed against the order of the ld. CIT (Exemptions), Bangalore dated 24.03.2026 vide DIN & Notice No. ITBA/EXM/F/EXM45/2025-26/ 1087796276(1) rejecting the application filed for approval u/s 80G of the Income Tax Act, 1961 (in short “the Act”).

2.

The assessee has raised the following grounds of appeal:- Sri Vrindavana Gokula Charitable Trust, Bengaluru

3.

The brief facts of the case are that the assessee is a charitable trust registered u/s 12AB(1)(b) of the Act on 08.03.2026 vide Unique Registration No. (URN)-AASTS7773E25BL0

The order continues below.

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