Society of St. Vincent De Paul Bondel Vs CIT (Exemptions) (ITAT, Bangalore)
Cash Donations Cannot Make Charity Disappear—ITAT Directs Registration u/s 12AB Where CIT(E)’s Own Table Proved Charitable Activities
The controversy
The assessee, Society of St. Vincent De Paul Bondel, Mangaluru, was registered under the Karnataka Societies Registration Act, 1960. Its stated objects included relief to the poor & medical relief.
The Society provided provisions to poor families, medical assistance & housing aid for repairs to needy persons. It was initially granted provisional registration u/s 12A(1)(ac)(vi) through Form No.10AC dated 30 December 2022 for three years.
Thereafter, the Society filed Form No.10AB on 29 June 2024 seeking regular registration u/s 12AB. The CIT(Exemptions), Bengaluru, rejected the application on 30 December 2024.
The rejection was based upon two conclusions: first, that the bank account contained mostly cash deposits and the alleged donations were not verifiable; second, that no donations had actually been received and no charitable activities had been carried out.
Fresh application became a procedural detour
Instead of immediately appealing against the rejection, the Society filed another Form No.10AB on 31 March 2025 for registration for the same period.
The CIT(E) rejected this second application on 4 September 2025, observing that filing a fresh application for the same period amounted to a collateral attack upon a concluded decision and undermined the statutory appellate framework.
