M/S. RAYA NAIK MEMORIAL GOWSHALA TRUST,KAJUBAG KARWAR vs. COMMISSIONER OF INCOME TAX (EXEMPTIONS) BANGALORE, UNITY BUILDING ANNEXE, MISSION ROAD, BANGALORE

ITA 1920/BANG/2025Status: DisposedITAT Bangalore27 January 2026AY 2024-25Bench: SHRI WASEEM AHMED (Accountant Member), SHRI SOUNDARARAJAN K (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the scope of enquiry under Section 12AB is limited to the charitable nature of objects and genuineness of activities, not detailed financial scrutiny. Issues like donor creditworthiness and asset ownership are beyond the registration stage.

What were the facts?

The assessee, a trust engaged in animal welfare, applied for regular registration under Section 12AB. The CIT(E) rejected the application citing discrepancies in cow numbers, low fodder expenditure, unverified donor creditworthiness, and trust assets being owned by a trustee.

What were the issues?

Whether the CIT(E) can reject a registration application under Section 12AB based on issues like donor creditworthiness and asset ownership, which are typically examined at the assessment stage.

Which sections of the Income-tax Act were involved?

Section 12AB,Section 12A(1)(ac)(vi),Section 2(15)

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Income Tax Appellate Tribunal, ‘B’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI SOUNDARARAJAN K

For Appellant: Shri Siddesh Gaddi, CA
For Respondent: Shri Muthu Shankar, CIT (DR)
Hearing: 20.01.2026Pronounced: 27.01.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The present appeal has been instituted by the assessee against the rejection order of the Ld. CIT(E) u/s 12AB of the Act in Form No. 10AD dated 26-06-2025. 2. The assessee in the memo of appeal raised multiple grounds numbered 1 to 13, which we, for the sake of brevity and convenience are not inclined to reproduce here.

3.

The ground of appeals filed by assessee is limited to the issue of rejection order of the Ld. CIT(E) u/s 12AB of the Act in Form No. 10AD.

4.

The brief facts are the assessee, a trust, is engaged in charitable activities relating to animal welfare such as providing shelter, care etc. to abandoned and s

The order continues below.

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