TAKSHILA SPORTS FOUNDATION vs. COMMISSIONER OF INCOME TAX (EXEMPTION), DELHI
What did the High Court hold?
The Delhi High Court held that the reason provided by the respondent for rejecting the petitioner's applications for registration – failure to provide a list of donors, bills/vouchers for expenses, source of funds, and list of beneficiaries – was based on the petitioner's inability to furnish these due to the accountant's leave, which constituted a bona fide reason. While acknowledging the petitioner's obligation to produce documents, the Court found that some indulgence could have been granted given the request for adjournment with a valid reason, especially as it led to the rejection of registration applications. Consequently, the Court quashed and set aside the impugned orders dated March 22, 2026. The petitioner was directed to produce all required documents by May 18, 2026. The respondent was then to consider these documents, issue further notices if necessary, and pass a fresh order by June 30, 2026. The Court noted that hearing an appeal would take substantial time and no detailed arguments on merit were required.
What were the facts?
The petitioner, Takshila Sports Foundation, filed a writ petition challenging orders dated March 22, 2026, which rejected its applications for registration under Section 12A(1)(ac)(ii) and Section 12AB of the Income Tax Act, 1961, and cancelled its provisional registration under Section 80G(5). The petitioner had received notices on December 29, 2025, and March 8, 2026, requesting information. While most information was provided by March 18, 2026, some bills and vouchers remained outstanding due to the accountant's unavailability. The petitioner requested more time, but the respondent, Commissioner of Income Tax (Exemption), Delhi, passed the impugned orders on March 22, 2026, citing non-production of these documents.
What were the issues?
1. Whether the rejection of the petitioner's applications for registration under Section 12A(1)(ac)(ii) read with Section 12AB of the Act of 1961 and cancellation of provisional registration under Section 80G(5) of the Act of 1961, solely on the ground of non-production of certain bills and vouchers, despite a request for adjournment with a bona fide reason, was justified? Assessee's Contentions: The petitioner argued that the rejection was arbitrary as it was based on the non-production of a few bills and vouchers, which could have been provided if some time was granted. The reason for the delay, the unavailability of the accountant, was bona fide. The petitioner asserted that the respondent did not grant even a 'breathing time' despite the request. Revenue's Contentions: The respondent submitted that since the petitioner could avail the remedy of appeal before the Income Tax Appellate Tribunal (ITAT), the High Court should not entertain the writ petition under Article 226 of the Constitution of India.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
O R D E R %
2026
By way of the present writ petition, the petitioner-trust has challenged orders dated 22.03.2026 qua which the petitioner’s applications for registration under Section 12A(1)(ac)(ii) read with Section 12AB of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act of 1961’) were rejected and provisional registrations under Section 80G(5) of the Act of 1961 were cancelled.
Learned counsel for the petitioner submitted that the petitioner trust, which was granted provisional registration in December, 2023, is engaged in This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/05/2026 at 12:51:16
various sport activities and establishing yoga centres and sports complexes.
He submitted that during the course of proceedings for grant of regular registration under Section 12A(1)(ac)(ii) of the Act of 1961, the petitioner firstly received a notice on 29.12.2025, in response whereof, it furnished requisite information. Whereafter, another notice dated 08.03.2026 came to be issued requiring the petitioner to furnish some more details, out of which, most of the details had been furnished by the petitioner on 18.03.2026, barring a few bills and vouchers asked for by the respondent- Commissioner of Income Tax (Exemption), Delhi. He asserted that qua which, a request was made by the petitioner that some more time be allowed, as the concerned accountant of the petitioner-trust was not available in town.
He submitted that in spite of such request, the respondent did not give even a breathing time to the petitioner-trust and passed impugned orders on 22.03.2026, cancelling petitioner’s provisional registrations and approvals, simply because vouchers and bills were not produced by the petitioner.
Learned counsel for the petitioner further submitted that bills and vouchers are ready and the same could have been produced if some time was granted.
Mr. Gaurav Gupta, learned Senior Standing Counsel for the respondent at the outset submitted that since the petitioner can avail the remedy of appeal before the Income Tax Appellate Tribunal (ITAT), this Court should not entertain the present writ petition invoking its extraordinary writ jurisdiction under Article 226 of the Constitution of India.
Heard learned counsel for the parties.
On perusal of the impugned order and what has been stated at bar by This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/05/2026 at 12:51:16
learned counsel for the petitioner, we find that essentially, the reason given by the respondent for rejecting the petitioner’s applications for registration is that the petitioner failed to provide list of donors, bills/vouchers for expenses claimed, source of funds received and list of beneficiaries, which according to the petitioner were not furnished on account of accountant being on leave, which according to us, constitute a bona fide reason.
Though, it was incumbent upon the petitioner to produce all the documents, as and when called upon by the respondent, but since the petitioner had moved a request for adjournment inter alia indicating a valid reason, we are of the view that some indulgence could have been granted to the petitioner. More particularly, because the same has resulted in rejection of the petitioner’s applications for registration under Section 12A(1)(ac)(ii) of the Act of 1961. 10. We are therefore, inclined to set aside the impugned order while giving the petitioner a liberty to produce all the documents as required by the respondent because hearing of appeal will take substantial time and no detailed arguments on merit are required.
The impugned orders dated 22.03.2023 (Annexures P1 and P2) rejecting the applications for registration and cancelling the provisional registrations are hereby quashed and set aside.
The petitioner shall produce all the documents as required by respondent on 18.05.2026, alongwith a web copy of the order instant. On receipt of the documents, the respondent-Commissioner of Income Tax (Exemption), Delhi shall consider the same and issue a notice to the petitioner in case any further information is necessary, whereafter he shall pass a fresh order in accordance with law. This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/05/2026 at 12:51:16
The time for passing such order shall stand extended up to 30.06.2026 before which the respondent has to pass an order.
DINESH MEHTA, J
AMIT MAHAJAN, J MAY 8, 2026/cd
This is a digitally signed order. The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 14/05/2026 at 12:51:16
More judgments on Section 12A(1)(ac)(ii)
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- Ss Early Learning Society, Hyderabad vs CIT (Exemption), HyderabadITA 1208/HYD/2025[2026-27]Status: Disposed16 Oct 2026AY 2026-27
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- Lalaram Charitable Trust, Agra vs ITO, Exemption, AgraITA 659/AGR/2026[2025-26]Status: Disposed15 Oct 2026AY 2025-26
- Shri Brajshiromani Laxmandas Sewa Trust… vs Income-Tax Officer, Ward 1(3)(1), Mathura…ITA 592/AGR/2026[2026-2027]Status: Disposed14 Oct 2026AY 2026-2027
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