HANDS ON CSR TRUST,BANGALORE vs. CIT, (EXEMPTIONS) , BANGALORE

ITA 264/BANG/2025Status: DisposedITAT Bangalore13 October 2025Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)7 pages
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What did the Tribunal hold?

The Tribunal held that for registration under Section 12AB, the genuineness of activities, not the quantum of expenditure, is relevant. The CIT(Exemptions) erred in rejecting the application solely on the basis of expenditure.

What were the facts?

The assessee trust applied for registration under Section 12AB of the Income Tax Act. The CIT(Exemptions) rejected the application, observing that the trust had not made substantial expenditure towards its objects and had not commenced its activities.

What were the issues?

Whether the genuineness of activities or the quantum of expenditure is the primary criterion for granting registration under Section 12AB of the Income Tax Act.

Which sections of the Income-tax Act were involved?

Section 12AB

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

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

Hearing: 15.07.2025Pronounced: 13.10.2025

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 17.12.2024 vide DIN & Notice No. ITBA/EXM/F/EXM45/2024- 25/1071305748(1) cancelling the registration u/s 12AB of the Income Tax Act, 1961 (in short “The Act”).

2.

The assessee has raised the following grounds of appeal: Hands On CSR Trust, Bangalore 3. Brief facts of the case are that the assessee trust was constituted vide Deed of Trust dated 17.1.2022 at Bangalore with the object of carrying out Charitable activities, assisting people in development progra

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