Blaze Trust Vs CIT (ITAT Chennai)
The Income Tax Appellate Tribunal (ITAT), Chennai, adjudicated an appeal filed by the assessee against the order of the Commissioner of Income Tax (Exemption), Chennai, dated 29.08.2024, rejecting approval under Section 80G of the Income Tax Act, 1961. The appeal was filed with a delay of 118 days; however, upon consideration of the affidavit explaining the delay, the Tribunal condoned it and proceeded to examine the case on merits.
The assessee is a public charitable trust incorporated on 25.09.2003. It had applied for registration under Section 80G(5)(iii) through Form 10AB on 20.02.2024. The Commissioner rejected the application on the ground that the activities of the trust were in the nature of a business correspondent, treating them as micro-finance activities that were not charitable in nature.
Before the Tribunal, the assessee contended that its objects included socio-economic empowerment of marginalized communities, promotion of human rights, provision of food, shelter, medical aid and education, establishment of welfare institutions, and implementation of development programmes. It further submitted that its activities, such as facilitating bank account operations, pension disbursement, and acting as an intermediary in welfare delivery systems, were integrally connected with its charitable objectives and carried out without profit motive.
