ROONGTA WELFARE FOUNDATION,SURAT vs. CIT(EXEMPTION),AHEMDABAD, AHEMDABAD

ITA 228/AHD/2026Status: DisposedITAT Ahmedabad12 March 2026Bench: SHRI SIDDHARTHA NAUTIYAL (Judicial Member), SHRI NARENDRA PRASAD SINHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the CIT(Exemptions) rejected the application primarily on the ground that the assessee did not hold a valid registration under Section 12A/12AB. However, the assessee produced a provisional registration certificate under Section 12A in Form No. 10AC, which was valid at the time of application.

What were the facts?

The assessee, a charitable trust, applied for approval under Section 80G(5) and Form No. 10AB. The CIT(Exemptions) rejected the application, stating the assessee lacked valid registration under Section 12A/12AB at the time of application.

What were the issues?

Whether rejection of application for approval under Section 80G(5) by CIT(Exemptions) was justified on the ground of lack of valid registration under Section 12A/12AB, when the assessee possessed provisional registration.

Which sections of the Income-tax Act were involved?

Section 80G(5),Section 10AB,Section 12A,Section 12A/12AB,Section 10AD,Section 10AC,Section 10(23C)

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Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SIDDHARTHA NAUTIYAL & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Rasesh Shah, AR
For Respondent: Shri Alpesh Parmar, CIT DR
Pronounced: 12.03.2026

PER SIDDHARTHA NAUTIYAL - JUDICIAL MEMBER:

This appeal has been filed by the Assessee against the order passed by the Ld. Commissioner of Income Tax (Exemption), (in short “Ld. CIT(E)”), Ahmedabad vide order dated 21.11.2025. 2. The assessee has taken the following grounds of appeal:

“1. Grounds of Appeal On the facts and in circumstances of the case as well as law on the subject, the learned CIT(E) has erred in rejecting the application of assessee for approval u/s. 80G(5) of the Act without giving reasonable and sufficient opportunity of being heard.

2.

On the facts and in circumstances of the case as well as law on the subject, the learned CIT(Exe

The order continues below.

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