D.R. Shanmukappa Charitable Trust Vs CIT (Exemptions) (ITAT Bangalore)
The Income Tax Appellate Tribunal (ITAT) considered the assessee’s appeal against the order of the Commissioner of Income Tax (Exemptions) dated 24.09.2025 rejecting the application for registration under Section 12AB of the Income-tax Act, 1961.
At the outset, the Tribunal dealt with the delay in filing the appeal. The assessee filed an application for condonation of delay supported by an affidavit of the trustee, Preethi D.S., stating that she was suffering from health issues, received medical treatment, and was advised complete bed rest for fifteen days. A medical certificate issued by Manas Multispeciality Hospital dated 20.11.2025 was also produced. After considering the explanation and hearing both parties, the Tribunal held that sufficient cause had been shown and condoned the delay in filing the appeal.
The Tribunal then examined the background of the dispute. The assessee trust was constituted by a Trust Deed dated 01.03.2021 at Bengaluru and claimed to be carrying on charitable activities falling within the scope of Section 2(15) of the Act. The trust initially applied for registration under Section 12AB in Form No. 10AB on 08.11.2023. This application was rejected on 13.05.2024 on the ground that the assessee had not responded to notices or furnished the required documents.
