Tiger Research an Conservation Trust Vs ITO (ITAT Nagpur)
The Tiger Research and Conservation Trust appealed to the Income Tax Appellate Tribunal (ITAT) Nagpur after the Commissioner of Income Tax (Exemption), Pune, rejected their application for 80G approval. The CIT(E) had raised concerns regarding the trust’s financial management, specifically the large sums of money held in bank accounts and fixed deposits, deeming them idle and not utilized for the trust’s stated objectives. The CIT(E) also pointed to the trust’s failure to provide adequate documentation, such as bills, vouchers, research activity papers, and details of foreign contributions received. The trust, however, argued that it had valid 12AB registration, implying that its activities were already deemed compliant, and that its 80G approval should also be valid until assessment year 2026-2027. They presented documentation demonstrating the utilization of FCRA funds and financial statements from 2021-22 to 2023-24, asserting that they had met all statutory requirements.
During the ITAT hearing, the trust’s counsel emphasized the validity of their 12AB registration and the prior grant of 80G approval, arguing that the CIT(E)’s rejection was based on a misrepresentation of facts. They contended that the funds held in bank accounts and FDRs were not idle but were being used to support the trust’s conservation and research activities, especially considering the importance of tiger conservation in India. The ITAT reviewed the documents submitted by the trust, including financial statements, FCRA fund utilization details, and registration certificates. They concluded that the trust had adequately demonstrated the utilization of its funds for its stated objectives and that the CIT(E)’s assessment was unjustified. The ITAT acknowledged the significance of the trust’s work in protecting and researching tigers, a national animal, and emphasized the need to encourage such activities. Consequently, the ITAT overturned the CIT(E)’s order, reinstating the 80G approval for the Tiger Research and Conservation Trust, and allowing the appeal of the trust.
