ITAT Jodhpur Judgments — August 2026

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.

The Tribunal held that the rejection of Section 80G approval was consequential to the absence of valid Section 12AB registration. In the four appeals where fresh Section 12AB applications were pending, the Tribunal set aside the impugned orders and restored the Section 80G applications to the CIT(E). The CIT(E) was directed to first decide the pending Section 12AB applications and thereafter consider the Section 80G applications in light of the outcome. In the appeal where Section 12AB registration had been granted, the Tribunal also set aside the impugned order and restored the Section 80G application to the CIT(E). The CIT(E) was directed to reconsider the Section 80G application taking into account the subsisting Section 12AB registration. The Tribunal explicitly stated that it had not expressed any opinion on the satisfaction of other statutory conditions for Section 80G approval, which would be examined by the CIT(E). The ratio is that consequential orders based on a factual premise that is subject to pending adjudication or has subsequently changed, require reconsideration by the original authority.

The Tribunal held that since no Form No. 10-IE withdrawing the option was filed, the CIT(A)'s finding of withdrawal was factually incorrect. The AO was directed to verify the absence of a withdrawal form and compute tax under the new regime.

The Tribunal condoned the delay of 58 days, finding the assessee's explanation to be reasonable and bona fide. The appeal was restored to the CIT(A) for adjudication on merits.

The Tribunal condoned the 25-day delay in filing the appeal before the CIT(A) as the explanation was plausible and the delay was marginal. The Tribunal also set aside the ex parte assessment order and restored the matter to the Assessing Officer for fresh adjudication.

The Tribunal found that the assessee's contention regarding timely deposit of contributions required verification. The issue was restored to the Assessing Officer for verification of the challans and due dates.

The Tribunal found no reason to keep the appeal pending as the assessee's grievance no longer survived due to subsequent developments. The assessee's request for withdrawal was accepted.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the nomenclature "provision expenses" was a misinterpretation. The expenditure was for actual purchases of day-to-day consumables and housekeeping items, and payments were made. Therefore, the disallowance was erroneous.

The Tribunal held that the CIT(E)'s rejection was based on an erroneous appreciation of facts and law. The Tribunal found that provisional registrations/approvals were granted and the interpretation of the trust's beneficiaries as a particular caste was not sufficiently examined.

The Tribunal held that the CIT(E)'s rejection was based on an erroneous appreciation of facts and law. The Tribunal found that provisional registrations/approvals were granted and the interpretation of the trust's beneficiaries as a particular caste was not sufficiently examined.

The CIT(A) erred by adjudicating an appeal for AY 2011-12 when the appeal filed was for AY 2010-11. The appellate order for AY 2011-12 is unsustainable as it was passed without jurisdiction and without affording an effective opportunity of hearing for the correct appeal.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal upheld the CIT(A)'s deletion of additions. The jewellery was considered reasonably explained based on family status and CBDT instructions. The guar-gum stock was found to be properly recorded in the father's business accounts with supporting documentation.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.

The Tribunal held that the Assessing Officer's order was not erroneous as it was based on a binding jurisdictional High Court judgment. Therefore, the Principal Commissioner's revisionary order under section 263 was unsustainable.

The Tribunal held that the CIT(Exemption) erred in rejecting the applications based on a general apprehension of non-genuineness. The voluminous documentary evidence, including cattle registers with government verification and financial statements, sufficiently proved the genuineness of the activities.

The Tribunal held that the assessee had provided substantial documentary evidence to prove the genuineness of its activities and charitable objects. The objections raised by the CIT(E) were found to be factually incorrect or not sustainable based on the evidence.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that the impugned orders of the CIT(E) were not to be treated as final rejections but rather as directions for further proceedings. The Tribunal categorized the appeals based on the nature of deficiencies and provided specific directions for each category. For instance, where registration under the Rajasthan Public Trust Act was pending, the Tribunal directed the CIT(E) to verify the certificate upon issuance and proceed with the section 12AB application without requiring the assessee to restart the entire process. For issues concerning the genuineness of activities, the Tribunal directed a fresh examination based on primary material, emphasizing that previous failure to establish genuineness would not automatically constitute a positive finding of non-genuineness. Procedural defects were to be rectified, and applications adjudicated on merits. Rejection of section 80G approval, often consequential to the absence of section 12AB registration, was to be considered after or alongside the determination of section 12AB proceedings. The Tribunal stressed that the restored proceedings should not be a wholesale de novo enquiry but should correspond to the precise deficiency that led to the impugned order. The ultimate eligibility of the assessees was left open for determination by the prescribed authority.

The Tribunal held that registration under section 12AB is not a mandatory precondition for 80G approval if the assessee's income is otherwise exempt under section 10(23C). The CIT(E) erred by not examining the assessee's claim of exemption under section 10(23C)(iiiad).

The Tribunal condoned the delay, finding sufficient cause. It held that the assessee's objects were charitable, its activities were genuine and supported by documentary evidence, and the financial position showed deficits, negating the claim of improper benefit availing. The registration under the Rajasthan Public Trust Act was also confirmed.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.

The Tribunal held that the impugned orders of the CIT(E) were not based on proper consideration of all aspects. It directed the CIT(E) to re-examine the applications based on specific categories of deficiencies, allowing for rectification of procedural defects and further inquiries where necessary.