Guru Nanak Trust of Education Vs CIT (ITAT Amritsar)
Running a School Is Undisputedly a Charitable Activity: Amritsar ITAT Restores Trust’s Section 12AB Registration Application for Fresh Consideration
The Amritsar ITAT restored the application of Guru Nanak Trust of Education for registration under Section 12AB to the CIT(E) for fresh consideration. The CIT(E) had rejected the application after noticing substantial cash deposits and expressing doubts about the source of donations, genuineness of activities and financial integrity of the trust.
The Tribunal observed that the trust was actually running a school, which constituted education and qualified as a charitable activity under Section 2(15). In the interest of justice, it directed the CIT(E) to reconsider the application afresh, keeping in view the charitable activities genuinely carried on by the trust. The assessee was directed to furnish all supporting documents concerning the donations and cash deposits and cooperate with the proceedings. The CIT(E) was also directed to provide a reasonable opportunity of hearing.
FULL TEXT OF THE ORDER OF ITAT AMRITSAR
This appeal is filed by the assessee against the order of the Ld CIT (E),
Chandigarh, dated 20/03/2025, rejecting the application for registration dated 04/09/2024, filed by the assessee in Form 10AB, u/s 12(1)(ac)(vi)(B) of the Income Tax Act 1961(henceforth the Act).
