Ram Gopal Temple Trust Vs CIT (Exemptions) (ITAT Chandigarh)
The appeal before the Income Tax Appellate Tribunal (ITAT) Chandigarh concerned the rejection of an application filed by Ram Gopal Temple Trust (the assessee) seeking registration under Section 12A(1)(ac)(iii) of the Act. The application was rejected by the Commissioner of Income Tax (Exemption), Chandigarh [CIT(E)], via an order dated November 25, 2024.
The primary reason cited by the Ld. CIT(E) for the rejection was the assessee’s failure to furnish the trust deed, which prevented the verification of the trust’s objects. The impugned order referred to Rule 17A of the Income Tax Rules, which mandates the filing of a certified copy of the instrument creating or establishing the trust. If the trust is created otherwise than under an instrument, a self-certified copy of the document evidencing its creation is required.
Assessee’s Details and Submissions
From the arguments put forth by the Ld. Authorized Representative (AR), it emerged that the assessee is a temple located in Village Damtal, Tehsil Nurpur, Distt. Kangra, commonly known as ‘Mandir Damtal’, ‘Shri Ram Thakur Ram Gopal Temple’, and ‘Shree Ram Gopal Temple Trust’. The institution initially came into existence around the year 1868.
The temple of Damtal was later taken over by the Government of Himachal Pradesh on January 3, 1996, as per the Himachal Pradesh Hindu Public Religious Institutions and Charitable Endowments Act, 1984 (HPPRICE). The administration and operations of the assessee-trust are directly overseen by the State Government and governed by the rules and regulations mentioned in the HPPRICE Act. The temple is managed by a committee appointed by the State Government, whose members include retired IAS and other Senior Government officers.
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