Raya Naik Memorial Gowshala Trust Vs CIT (Exemptions) (ITAT Bangalore)
The appeal was filed against the rejection order passed by the Commissioner of Income-tax (Exemptions) under section 12AB of the Income-tax Act in Form No. 10AD dated 26.06.2025. The dispute was confined to the rejection of the application for regular registration under section 12AB.
The assessee is a charitable trust engaged in animal welfare activities, including shelter, care and protection of abandoned and stray cattle through a gaushala. The trust had been granted provisional registration under section 12A(1)(ac)(vi) and subsequently applied for regular registration in Form No. 10AB on 28.11.2024.
The Commissioner rejected the application on several grounds. First, there was a mismatch between the number of cows stated in the trust’s submissions and the number reflected on its website. Second, the expenditure incurred on fodder was considered disproportionately low compared to the claimed number of cows. Third, the trust had received a donation of ₹25,00,000 from a donor, and the Commissioner held that the creditworthiness of the donor could not be verified as income-tax return details were not furnished. Fourth, the land and building used for running the gaushala were owned by one of the trustees, not the trust, raising doubts about asset ownership.
