Mahaveer Swami Panchsikhri Jinalya Trust Vs CIT (ITAT Jodhpur)
Summary: The appeal was filed by Shree Mahaveer Swami Panchsikhri Jinalya Trust against the order dated 14.03.2026 passed by the Commissioner of Income Tax (Exemption), Jaipur, rejecting the assessee’s application dated 27.09.2025 in Form No. 10AB for renewal of registration under section 12AB of the Income-tax Act, 1961.
The sole controversy before the ITAT was whether the CIT(E) was justified in rejecting the renewal application on the ground that the assessee was not registered under section 12A/12AA before 01.04.2021 and consequently could not have applied under clause (ii) of section 12A(1)(ac).
The assessee-trust was established on 11.10.2018 and was engaged in religious-cum-charitable activities, with objects covering religious purposes, relief of the poor, education, medical relief and advancement of objects of general public utility. It was subsequently registered under the Rajasthan Public Trust Act, 1959 on 08.07.2025.
After introduction of the new registration regime, the assessee applied for provisional registration and was granted registration through Form No. 10AC dated 27.05.2021 under section 12A(1)(ac)(vi) for Assessment Years 2021-22 to 2023-24. It thereafter applied for regular registration through Form No. 10A on 25.11.2022. While filing that application, clause (i) of section 12A(1)(ac) was selected. The Department accepted the application and granted regular registration through Form No. 10AC dated 02.12.2022 under sub-clause (i) of clause (ac) of section 12A(1), for Assessment Years 2022-23 to 2026-27.
