SANKALIT GRAM VIKASH TRUST,SIHOR vs. THE CIT(EXEMPTION), AHMEDABAD

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ITA 2030/AHD/2025Status: DisposedITAT Ahmedabad27 January 2026Bench: Shri Sanjay Garg, Judicial Member And Annapurna Gupta (Accountant Member)3 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. Citing a previous order where the issue of 12A registration was restored to the CIT(E), the Tribunal also restored the 80G approval issue to the CIT(E) to be decided along with the 12A application.

What were the facts?

The assessee-trust appealed against the rejection of its application for approval under section 80G of the Income Tax Act. The rejection was based on the prior rejection of its application for registration under section 12A. The appeal was filed with a delay of 59 days.

What were the issues?

Whether the rejection of 80G approval based on 12A rejection warrants a remand when the 12A issue itself is pending further adjudication.

Which sections of the Income-tax Act were involved?

Section 80G,Section 12A

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Annapurna Gupta

For Appellant: Shri Mehul K. Patel, Advocate
Hearing: 19/01/2026

"ी संजय गग", "ाियक सद" एवं अ"पूण" गु!ा, लेखा सद" के सम%। ] ] Before Shri Sanjay Garg, Judicial Member And Annapurna Gupta, Accountant Member आयकर अपील सं /ITA No.2030/Ahd/2025 िनधा"रण वष" /Assessment Year : NA Sankalit Gram Vikash Trust The CIT (Exemption) बनाम/ Building No.49, Anandnagar-Prahladnagar v/s. Ramdevnagar Road Near Dadani Vav, Sihor Ahmedabad – 380 015 Sihor – 364 240 "थायी लेखा सं./PAN: AABTS 0271 N (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee by : Shri Mehul K. Patel, Advocate Revenue by : Shri Rignesh Das, CIT-DR सुनवाई की तारीख/Date of Hearing : 19/01/2026 घोषणा की तारीख /Date of Pronouncement: 27 /01/2026 आदेश/O R D E R Per Sanjay Garg, Judicial Member:

The present appeal has been preferred by the assessee-trust against the order of the Learned Commissioner of Income Tax (Exemption), Ahmedabad [hereinafter referred to as ‘CIT(E)’] dated 26/06/2025, rejecting the application of the assessee-trust for approval u/s.80G of the Income Tax Act, 1961 (for short “the Act”).

2.

The appeal is time-barred by 59 days. A separate application for condonation of delay has been filed. Considering the averments made in the Sankalit Gram Vikash Trust vs. The CIT(E)

2 application as well as the shortness of delay, the delay in filing the appeal is hereby condoned.

3.

At the outset, the Ld. Counsel for the assessee-trust has submitted that the application of the assessee for approval u/s.80G of the Act has been rejected on the ground that the assessee’s application for registration as a charitable institution u/s.12A of the Act already stood rejected. The Ld. Counsel for the assessee has furnished before us a copy of the order dated 16/10/2025 of this Tribunal passed in whereby, the issue relating to registration u/s.12A of the Act has been restored by the Tribunal to the file of Ld. CIT(E). Accordingly, the issue involved in the present appeal relating to approval u/s.80G of the Act is also restored to the file of the Ld. CIT(E) to be decided along with the application of the assessee for registration u/s.12A of the Act.

4.

In the result, the appeal of the assessee is treated as allowed for statistical purposes.

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