ROYAL DEEDS CHARITABLE TRUST,VIJAYAWADA vs. COMMISSIONER OF INCOME TAX (EXEMPTION), HYDERABAD

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ITA 522/VIZ/2024Status: DisposedITAT Visakhapatnam07 March 2025Bench: the Tribunal by raising the following grounds of appeal:5 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal found that the Ld. CIT (Exemption) rejected the application without properly specifying what constituted commercial activities and without due consideration of the documents submitted by the assessee. Therefore, the matter was remitted back to the Ld. CIT (Exemption) to re-examine the documents and submissions, and decide on the Section 80G registration after providing a reasonable opportunity of being heard to the assessee.

What were the facts?

Royal Deeds Charitable Trust applied for registration under Section 80G of the Income Tax Act, 1961, by filing Form-10AB. The Ld. CIT (Exemption) issued notices seeking documents and details, and despite submissions from the assessee, rejected the application on the grounds that the Trust's activities were commercial in nature and violated provisions of Section 12AB and 80G.

What were the issues?

Whether the CIT (Exemption) was justified in rejecting the assessee's Section 80G registration application without specifying commercial activities or considering submitted documents, and whether the rejection violated principles of natural justice.

Which sections of the Income-tax Act were involved?

Section 80G,Section 80G(5),Section 12AB

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, VISAKHAPATNAM BENCH, VISAKHAPATNAM

Before: SHRI K NARASIMHA CHARY, HON’BLE & SHRI S BALAKRISHNAN, HON’BLE

For Appellant: Smt. Manasa Meenakshi DVN
For Respondent: Dr. Satyasai Rath, CIT-DR
Hearing: 20/02/2025Pronounced: 07/03/2025

आदेश की प्रनतनलनप अग्रेनर्त /Copy of the order forwarded to:- ननधधाऩरती/ The Assessee – Royal Deeds Charitable Trust, 20-6-3/21, 1. Appala Raju Street, Ayodhya Nagar, Vijayawada, Andhra Pradesh- 520003. रधजस्व/The Revenue – Commissioner of Income Tax (Exemption), 2. Aayakar Bhawan, Opposite LB Stadium Basheer Bagh, Hyderabad, Telangana – 500004. 3. The Principal Commissioner of Income Tax, आयकर आयुक्त (अपील)/ The Commissioner of Income Tax 4. नवभधगीय प्रनतनननध, आयकर अपीलीय अनधकरण, नवशधखधपटणम/ DR, ITAT, 5. Visakhapatnam गधर्ा फ़धईल / Guard file 6.

आदेशधनुसधर / BY ORDER

Sr. Private Secretary ITAT, Visakhapatnam

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