SHREE AMRUTVAHINI GRAMVIKAS MANDAL,AHILYANAGAR vs. COMMISSIONER OF INCOME TAX EXEMPTION, PUNE, PUNE

ITA 3139/PUN/2026Status: DisposedITAT Pune13 October 20265 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the CIT(Exemption) erred in rejecting the application for approval under Section 80G. The Tribunal found that the facts of the present case were identical to a previous case, Hamal Mathadi Shramik Vikas Sanstha vs. CIT(Exemption), Pune (ITA No.1355/PUN/2026, dated 13.07.2026), in which both members of the current bench were parties. In that case, the Tribunal had directed the CIT(Exemption) to grant approval under Section 80G. The reasoning was that if the CIT(Exemption) had already verified and granted a subsequent registration (in that case, under Section 12A(1)(ac)(i)), it implied that the earlier registration was on record and verified. Therefore, rejecting the application for failure to submit a copy of the prior approval, which was presumably verified for the subsequent approval, was considered an error without due application of mind. The Tribunal, following its earlier decision, directed the CIT(Exemption) to grant approval under Section 80G. The ground raised by the assessee was allowed.

What were the facts?

The assessee, Shree Amrutvahini Gramvikas Mandal, filed an appeal against the order dated 27.06.2026 passed by the CIT(Exemption), Pune. The CIT(Exemption) rejected the assessee's application for approval under Section 80G of the Income Tax Act, 1961. The rejection was based on the ground that the assessee failed to provide a copy of its prior approval under Section 80G granted before 01.04.2021, instead submitting a copy of registration obtained on 24.09.2021 under Section 80G(5)(i). The assessee contended that the prior approval was already on record with the CIT(Exemption)'s office and was verified when granting the subsequent regular approval for 5 years. The assessee had filed its application in Form No. 10AB on 24.12.2025.

What were the issues?

1. Whether the learned CIT(Exemption) erred in rejecting the assessee's application for approval under Section 80G solely on the ground that the assessee failed to provide a copy of its prior approval granted before 01.04.2021, despite such approval being on record and verified for subsequent regular approval. Assessee's contentions: The assessee argued that the CIT(Exemption) rejected the application without appreciating that the prior approval under Section 80G was already in his record, as his office had issued it. The assessee also stated that a copy of this prior approval was filed with Form 10A on 30.08.2021, and it was after verification of this document that the CIT(Exemption) granted the regular approval for 5 years. The assessee relied on the fact that the CIT(Exemption)'s office would have verified the earlier record before issuing the subsequent registration. Revenue's contentions: The revenue, through the CIT-DR, did not present any specific arguments beyond what was stated in the CIT(Exemption)'s order, which was that the assessee failed to furnish the copy of the old registration prior to 01.04.2021 u/s 80G(5).

Which sections of the Income-tax Act were involved?

Section 80G,Section 80G(5),Section 80G(5)(i)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “B”, PUNE

For Appellant: Shri Prasad Bhandari
For Respondent: Shri Amit Bobde, CIT-DR

PER R.K. PANDA, VP:

This appeal filed by the assessee is directed against the order dated 27.06.2026 of the Ld. CIT(Exemption), Pune rejecting the application for grant of approval u/s 80G of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2.

The only effective ground raised by the assessee reads as under:

1.

On the facts and in the prevailing circumstances of the case and in Law, the learned CIT (Exemption) - Pune erred in rejecting the application of the assessee for seeking approval under section 80G merely on the ground that the assessee trust failed to provide the copy of approval granted under section 80G prior to 01.04.2021 without appreciating the fact that it is already in his record as his of

The order continues below.

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