JAGAN NATH RATAN LAL BANGUR TRUST,JAIPUR vs. CIT (EXEMPTION), JAIPUR, JAIPUR

ITA 935/JPR/2026Status: DisposedITAT Jaipur13 October 2026AY 2026-274 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal held that the application seeking approval under Section 80G of the Act should be restored back to the CIT(Exemption) to be examined afresh. This decision was based on the admitted fact that the assessee's application for registration under Section 12A was also rejected for identical reasons and had been restored by the ITAT for reconsideration. The Tribunal directed that the Section 80G application be examined along with the Section 12A application, following the directions given by the ITAT in the assessee's appeal in ITA No.934/JPR/2026. The reasoning was that since the ITAT had already directed a fresh examination of the Section 12A application due to the assessee rectifying the deficiencies, a similar approach was warranted for the Section 80G application. The appeal was allowed for statistical purposes.

What were the facts?

The assessee, Jagan Nath Ratan Lal Bangur Trust, filed an appeal against the order of the CIT(Exemption), Jaipur, dated 12.02.2026, which denied approval under Section 80G of the Income Tax Act, 1961. The denial was based on the grounds that the assessee had filed an incomplete Form 10AB and was not registered under the Rajasthan Public Trust Act, 1959. The CIT(E) also noted that approval under Section 80G cannot be granted without registration under Section 12AB. The assessee contended that in identical circumstances, their application for registration under Section 12A was also rejected by the CIT(E) but was subsequently restored by the ITAT for fresh examination in ITA No.934/JPR/2026. The Revenue's representative conceded that the Section 12A application was rejected for similar reasons and restored by the ITAT.

What were the issues?

1. Whether the CIT(Exemption) was justified in denying approval under Section 80G of the Income Tax Act, 1961, on the grounds of an incomplete Form 10AB and non-registration under the Rajasthan Public Trust Act, 1959, when a prior application for registration under Section 12AB was rejected for similar reasons. Assessee's Contention: The assessee argued that their application for registration under Section 12A, rejected by the CIT(E) for identical reasons (incomplete Form 10AB and non-registration under the Rajasthan Public Trust Act, 1959), was restored by the ITAT in ITA No.934/JPR/2026. They submitted that they had since obtained the Rajasthan Public Trust Act registration and all other required documents, which were part of the department's record from previous approvals under the old regime. They relied on the ITAT's order in ITA No.934/JPR/2026. Revenue's Contention: The Revenue's representative admitted that the application for registration under Section 12A was rejected for identical reasons and had been restored by the ITAT for fresh reconsideration.

Which sections of the Income-tax Act were involved?

Section 80G,Section 12AB,Section 12A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, JAIPUR BENCHES, “A” BENCH, JAIPUR

Hearing: 12.10.2026Pronounced: 13.10.2026

Per Annapurna Gupta, AM:- The present appeal has been filed by the assessee against the order passed by the CIT Exemption, Jaipur (hereinafter referred to as “Ld. CIT(E)”), dated 12.02.2026 denying grant of approval under Section 80G of the Income Tax Act, 1961 (hereinafter referred to as “the Act”).

P a g e | 2 Jagan Nath Ratan Lal Bangur Trust

2.

The Ld. CIT(E) has denied the approval for the reason that the assessee had filed incomplete Form 10AB and not registered under the Rajasthan Public Trust Act, 1959. His order reads as under:- The applicant filed an online application on 27.09.2025 in Form 10AB for seeking approval u/s 80G(5)(ii) of the Income Tax Act, 1961. Thereafter, following letter/s was/were i

The order continues below.

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