Sunder Nagar Satsang Sabha Vs CIT (Exemptions) (ITAT Mumbai)
The appeal concerned the rejection of an application filed by a trust seeking regular registration under section 12AB of the Income-tax Act. The trust was created on 22 June 2022 for operating a Gurudwara and carrying out religious and charitable activities. It was granted provisional registration in Form 10AC on 24 December 2022, valid up to Assessment Year 2025–26. The trust commenced its activities in May 2023 but failed to file Form 10AB within the prescribed period for regularisation of provisional registration. The application was eventually filed on 20 March 2025, resulting in a delay of about 16 months.
The Commissioner of Income Tax (Exemptions) issued a notice seeking an explanation for the delayed filing. The trust explained that the delay arose due to confusion regarding newly introduced provisions and a bona fide belief that the provisional registration was valid until 31 March 2026. It requested condonation of delay, stating that the lapse was unintentional and that denial of registration would cause hardship. The Commissioner rejected the application, holding that the trust had not shown reasonable cause for delay and had failed to avail the benefit of extensions granted by CBDT circulars, including Circular No. 7/2024. On this basis, the application for registration under section 12AB was rejected.
