SRI MUTHUMALAI MURUGAN TRUST,PUTHIRAGOUNDENPALAYAM vs. THE INCOME TAX OFFICER (EXEMPTIONS), SALEM

ITA 3802/CHNY/2026Status: DisposedITAT Chennai06 October 2026AY 2026-275 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal condoned the delay of 32 days in filing the appeal, citing the Hon'ble Supreme Court's decision in Collector, Land Acquisition Vs. MST.Katiji & Ors. (167 ITR 471) (SC), finding reasonable and sufficient cause. Regarding the main issue, the Tribunal held that the rejection of approval under Section 80G on the ground of the assessee being engaged in religious cum charitable purposes was incorrect. The Tribunal observed from the financial statements that the assessee's main activity was providing Annadanam (free meals) to poor people, which is purely a charitable activity. Furthermore, the revenue had previously granted Section 80G approval up to AY 2026-27 after considering the trust's activities, and there had been no change in these activities or objects. Therefore, the Tribunal directed the CIT(E) to grant the approval under Section 80G in accordance with the law. The appeal was allowed.

What were the facts?

The assessee, Sri Muthumalai Murugan Trust, a public charitable trust with valid registration under Section 12A, appealed an order dated 26.03.2026 by the Commissioner of Income Tax (Exemptions), Chennai (CIT(E)). The CIT(E) rejected the trust's application for renewal of approval under Section 80G of the Income Tax Act, 1961, for Assessment Year 2027-28 onwards. The ground for rejection was that the trust was established for religious and charitable purposes, making it ineligible for Section 80G approval. The appeal was filed with a delay of 32 days, for which the assessee filed a condonation petition.

What were the issues?

1. Whether the delay of 32 days in filing the appeal by the assessee is liable to be condoned? (Question of procedure) 2. Whether the rejection of approval under Section 80G of the Income Tax Act, 1961, by the CIT(E) on the ground that the assessee is established for religious and charitable purposes is correct, especially when the trust's primary activity is providing free meals (Annadanam) to the poor and it previously held Section 80G approval? Assessee's arguments: - The assessee argued that it had previously received approval under Section 80G from AY 2022-23 to 2026-27 without any change in its objectives. The earlier approval was granted after due verification of its objects and activities. - The assessee contended that the revenue should not take a different stand at the time of renewal. Revenue's arguments: - The revenue rejected the application on the ground that the trust was established for religious and charitable purposes, implying it was not purely charitable and thus ineligible for Section 80G approval.

Which sections of the Income-tax Act were involved?

Section 80G,Section 12A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI SS VISWANETHRA RAVI & MS. PADMAVATHY.S

For Respondent: Ms. R. Anitha, CIT

PER PADMAVATHY.S, A.M: This appeal by the assessee is against the order of the Commissioner of Income Tax (Exemptions), Chennai (in short "CIT(E)") dated 26.03.2026 denying approval u/s. 80G of the Income Tax Act, 1961 (in short "the Act").

2.

The assessee is a public charitable trust and is holding a valid registration u/s. 12A of the Act. The assessee made an application for renewal of approval u/s. 80G of the Act from AY 2027-28 and

The order continues below.

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