Radha Swami Satsang Dinod Vs CIT (ITAT Delhi)
Summary: The Income Tax Appellate Tribunal, Delhi Bench ‘F’, allowed the appeal filed by Radha Swami Satsang Dinod against the order dated 19.02.2026 passed by the Commissioner of Income Tax (Exemption), Chandigarh, rejecting the assessee’s application for approval under Section 80G of the Income-tax Act, 1961.
The assessee had filed an application for registration under Section 80G(ii) on 29.09.2025 in Form 10AB. The CIT(E) observed that the assessee was engaged in religious activities and that its activities were religious-cum-charitable. According to the CIT(E), the objects were not confined exclusively to charitable purposes and expressly included religious objects. The CIT(E) relied upon Section 80G(5), Explanation (3) and the decision of the Hon’ble Supreme Court in Upper Ganges Sugar Mills Ltd. v. CIT [1997] 93 Taxman 645 (SC), and rejected the application.
The assessee contended before the Tribunal that it had been founded for public charitable purposes and had consistently enjoyed registration under Section 12A and approval under Section 80G. It relied upon earlier approvals, scrutiny assessments accepting its charitable status, its operative registration under Section 12A, and several judicial precedents on consistency and eligibility for Section 80G. The assessee also contended that no valid show-cause notice had been issued before rejection.
