AYAANSH TRUST,JAIPUR vs. CIT(EXEMPTION), JAIPUR, JAIPUR

आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर
IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR

Jh jkBkSM+ deys'k t;UrHkkbZ] ys[kk lnL; ,oa Jh ujsUnz dqekj] U;kf;d lnL; ds le{k
BEFORE: SHRI RATHOD KAMLESH JAYANTBHAI, AM& SHRI NARINDER KUMAR, JM vk;dj vihy la-@ITA No. 111 & 112/JPR/2025

Ayaansh Trust
Room No. 1, Plot No. 46, Janak Vihar
Panchyawala, Jaipur.
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Vs.
The CIT-Exemption,
Jaipur.
LFkk;hys[kk la-@thvkbZvkj la-@PAN/GIR No.: AAHTA7846B vihykFkhZ@Appellant izR;FkhZ@Respondent fu/kZkfjrh dh vksjls@Assesseeby : Shri Shrawan Kumar Gupta, Adv.
jktLo dh vksjls@Revenue by: Ms. Alka Gautam (CIT) lquokbZ dh rkjh[k@Date of Hearing

:20/08/2025

mn?kks"k.kk dh rkjh[k@Date of Pronouncement: 20/08/2025

vkns'k@ORDER

PER: NARINDER KUMAR, Judicial Member.

This common order is to dispose of the above captioned both appeals, as common issue based on same facts is involved , and both appeals have been argued simultaneously.
2. Arguments heard. Files perused.
3. As per record, vide order dated 27.11.2024, Learned CIT(E) rejected two applications of the appellant-appellant i.e. one u/s 12A(1)(ac)(B) of the ITA No. 111 & 112/JPR/2025
Ayaansh Trust, Jaipur.
2

Income Tax Act, 1961 (hereinafter referred to as “the Act”) submitted on 16.07.2024, and another application u/s 80G(iv)(B) of the Act.
4. First mentioned application has been rejected on the following ground:-
 Not furnished evidence of genuineness of activities.
5. Second mentioned application came to be dismissed as a consequence of dismissal of the first mentioned application, on the following ground:-
 Approval u/s 80G cannot be granted without registration u/s 12AB.
Contentions
6. Ld. AR for the appellant-applicant has submitted that entire material was made available to Learned CIT(E), but, even then the main application seeking registration u/s 12AB came to be rejected on the ground that the appellant-applicant had not furnished evidence of genuineness of activities.
Accordingly, the prayer is that impugned orders be set aside.
7. Para 2.4 of the impugned order, relating to the rejection of the application u/s 12AB, contains following observations made by Learned
CIT(E):-

ITA No. 111 & 112/JPR/2025
Ayaansh Trust, Jaipur.
3

“i) The applicant has not furnished details of activities carried during the F.Y.
2021-22, 2022-23 except one activity to help of elderly parents and wives of Army person during second wave of Corona Pandemic.
ii) On perusal of I&E account for the F.Y. 31.03.2022, it is found that total donation received during the year of Rs.66,000/- and claimed expenses of Rs.46,410/- as Programme Expenses and Rs.5540/- other expenses. In support of claim of expenses, the applicant has submitted only copy of cheques issued to beneficiaries totalling to Rs.24,500/- and no further details of activity details bill vouchers, photos has been submitted.
iii) Further, as per the reply it s submitted that all amount of donation has been received during F.Y. 2020-21, 20:21-22 and 2022-23 from Col. Vijay Chaudhary.

As per the I&E A/c for the year 31.03.2023 total donation received of Rs.45,000/- and claimed expenses of Rs.35,600/- as other expenses, however, no details of activity bill vouchers, photos has been provided by the applicant.
Therefore, from the above discussion, it is held that as per the reply/documents submitted the applicant’s activities are non-genuine thus application for registration u/s 12A is liable to be rejected.”

ITA No. 111 & 112/JPR/2025
Ayaansh Trust, Jaipur.
4

activities were submitted before Learned CIT(E), such entire evidence was required to be discussed while disposing of the two applications.
In para 2.3, Learned CIT(E) specified details/information/documents required from the applicant as per show cause notice dated 07.11.2024. However, in the paper book, we do not find copy of any bills/voucher.
In view of the copies submitted before this Appellate Tribunal in the form of paper book (from page 4 to 12), it cannot be said that the entire information/details/documents, as desired vide show cause notice dated
07.11.2024 were made available to Learned CIT(E).
11. In the given situation, keeping in view the issue involved, and in the interest of justice, we deem it a fit case to restore the matter to Learned
CIT(E) so as to afford to the appellant another opportunity of being heard, and to dispose of the two applications afresh.
Result
12. In view of the above findings, both appeals are disposed of, for statistical purpose, and while setting aside the impugned orders, both applications submitted before Learned CIT(E) are restored to his files with direction for disposal, in accordance with law, after affording to the applicant another opportunity of being heard.

ITA No. 111 & 112/JPR/2025
Ayaansh Trust, Jaipur.
5

Copy of the common order be also placed in the connected appeal file.
Files be consigned to the record room after the needful is done by the office.

Order pronounced in the open court on 20/08/2025. ¼jkBkSM+ deys'k t;UrHkkbZ ½

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(RATHOD KAMLESH JAYANTBHAI)

(NARINDER KUMAR) ys[kk lnL; @Accountant Member U;kf;d lnL;@Judicial Member

Tk;iqj@Jaipur fnukad@Dated:- 20/08/2025
*Santosh
आदेश की प्रतिलिपिअग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू
1. The Appellant- Ayaansh Trust, Jaipur.
2. izR;FkhZ@ The Respondent- CIT(Exemption), Jaipur.
3. vk;djvk;qDr@ The ld CIT
4. विभागीय प्रतिनिधि] आयकर अपीलीय अधिकरण] जयपुर@क्त्ए प्ज्Aज्ए Jंपचनत
5. xkMZ QkbZy@ Guard File ITA No. 111 & 112/JPR/2025) vkns'kkuqlkj@ By order,

सहायक पंजीकार@Aेेजज. त्महपेजतंत