Yakshit Yuva Foundation Vs CIT Exemption (ITAT Panaji)
The Income Tax Appellate Tribunal (ITAT), Panaji Bench, considered two appeals filed by a public charitable trust against orders of the Commissioner of Income Tax (Exemptions), Bangalore, dated 26 June 2025. The orders had rejected the trust’s applications for regular registration under Section 12AB and recognition under Section 80G of the Income-tax Act, 1961.
The trust was established on 14 November 2022 and registered on 16 November 2022. It had earlier obtained provisional registrations under Section 12AB and Section 80G on 24 March 2023. These provisional registrations were valid from Assessment Year (AY) 2023-24 to AY 2025-26. Subsequently, the trust filed applications in Form 10AB on 13 December 2024 seeking regular registration under Section 12AB and recognition under Section 80G.
The Commissioner rejected the applications on two primary grounds. First, the applications were considered time-barred because the trust had commenced activities before receiving provisional registration and therefore was required to apply for regular registration within six months of the provisional registration. The trust had filed the applications beyond that period. Second, the Commissioner concluded that the trust’s predominant activity—providing taekwondo training—did not qualify as a “charitable purpose” under Section 2(15) of the Act. Consequently, the application for Section 12AB registration was rejected, and the application for Section 80G recognition was also denied on similar grounds.
