MANJREKAR FOUNDATION,PUNE vs. CIT, EXEMPTION, PUNE, PUNE

ITA 2338/PUN/2025Status: DisposedITAT Pune27 January 2026Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)15 pages
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What did the Tribunal hold?

The Tribunal held that the assessee's application was filed within the time allowed under the Act, interpreting the statutory provisions to avoid absurdity. The CIT(Exemption) was directed to treat the application as valid and verify the assessee's eligibility.

What were the facts?

The assessee filed an application for approval under Section 80G of the Income Tax Act. The CIT(Exemption) rejected the application as time-barred, stating it was filed beyond the six-month period from the commencement of activities or provisional approval.

What were the issues?

Whether the application for 80G approval was filed within the prescribed statutory time limit, considering the commencement of activities and provisional approval.

Which sections of the Income-tax Act were involved?

Section 80G

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Income Tax Appellate Tribunal, PUNE BENCHES “A” :: PUNE

Before: DR.DIPAK P. RIPOTE & SHRI VINAY BHAMORE

For Appellant: Smt Deepa Khare
For Respondent: Shri Amol Khairnar – CIT(DR)
Hearing: 22/01/2026Pronounced: 27/01/2026

PER DR. DIPAK P. RIPOTE, AM: This appeal filed by the Assessee is against the order of ld.Commissioner of Income Tax(Exemption), passed under section 80G of the Income Tax Act, 1961 dated 30.08.2025. The Assessee has raised the following grounds of appeal : ―1. The Ld. CIT Exemption erred in law and on facts in treating the application under Clause (iii) of first proviso to sub-section (5) of Section 80G as non- maintainable on the ground of being filed beyond the statutory period as provided in Clause (iii) of first proviso to Section 80G (5) and thereby rejecting the same without going into the merits.

The order continues below.

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