SHRI PADMANABH SWAMI MATH DHULIA.,DHULE vs. COMMISSIONER OF INCOME TAX (EXEMPTION), PUNE

I.T.A.No.557/PUN/2025 Shri Padmanabh Swami CIT (Exemptions), Pune. Math Dhulia, 3492 Samadhi Mandir, Agra Road, Dule-424001, vs. Maharashtra PAN : AAJTS 7133 H (Appellant) (Respondent) For Assessee : None For Revenue : Shri Amit Bobde, CIT-DR Date of Hearing : 04.12.2025 Date of Pronouncement : 01.01.2026 ORDER PER ASTHA CHANDRA, JM :

This appeal filed by the assessee is directed against the order of Ld. Commissioner of Income Tax (Exemption), Pune [“CIT(E)”], dated 20.12.2024 passed under section 12AB of the Income Tax Act, 1961 (the “Act”) whereby he rejected the application for grant of regular registration u/s. 12A(1)(ac) of the Act.

2 ITA.No.557/PUN/2025 (Shri Padmanabh Swami Math Dhulia) 3. The grounds of appeal raised before us is against the findings of Ld.CIT(E) rejecting the assessee’s application for regular registration u/s. 12A(1)(ac) of the Act filed by the assessee on 26.06.2024.

4. Referring to para 6, 6.1 and 7 of the Ld. CIT(E)’s order, the Ld. DR submitted that the Ld. CIT(E) has rightly rejected the application of the assessee and also cancelled the provisional registration granted earlier by observing as under: “6. The applicant furnished response on 02/12/2024. Its submissions in response to the queries raised, particularly clause 2(i) and clause 2(vi) of the reply, have been carefully examined. It is, however, not found to be acceptable so as to prove the claim of carrying out charitable activities or to provide evidence supporting the genuineness of its operations. As per clause 2(i) of the reply, the trust admitted that its objectives are primarily religious, involving the worship of Shri Padmanabh Swami Samadhi and the performance of related religious functions. The trust has detailed routine and periodical religious ceremonies, such as daily pooja and annual events like Shri Datta Jayanti and Shri Padmanabh Swami Punyatithi. While these activities may align with the trust's objectives as stated in its deed, they are explicitly religious in nature and do not qualify as charitable activities. Further, the trust has not furnished any evidence of carrying out charitable activities that extend beyond its religious mandate, which contradicts its declaration in Form 10AB as a "charitable" trust. 6.1 In clause 2(vi), the trust claims to have uploaded bills and vouchers for the last three years on a Google Drive. However, no such submission is found on the portal. Actually, such a mode of submission is not an approved form of compliance under the procedural requirements. The trust was specifically required to furnish all relevant details and evidence through the e-filing portal. No other documentary evidence are furnished by the assessee for verification. Thus, the assessee failed to prove the genuineness of its purported activities. The trust has also failed to provide details of any charitable activities with specific dates and places, its beneficiaries or any credible evidence.

7. In view of the above, the undersigned is not satisfied about the charitable nature and the genuineness of activities of the assessee and compliance to requirements 3 ITA.No.557/PUN/2025 (Shri Padmanabh Swami Math Dhulia) of any other law for the time being in force by the trust / institution as are material for the purpose of achieving its objects. Therefore, the application filed by the assessee is hereby rejected and the provisional registration granted on 19/03/2022 under section 12AB read with section 12A(1)(ac)(vi) of the Income Tax Act, 1961 is hereby cancelled.

by the assessee are accordingly dismissed.