Mantra Yog Gau Seva Trust Vs CIT Exemption (ITAT Mumbai)
ncome Tax Appellate Tribunal (ITAT) Mumbai addressed an appeal by Mantra Yog Gau Seva Trust against the rejection of its applications for registration under Section 12A and approval under Section 80G of the Income Tax Act. The Commissioner of Income Tax (Exemptions) [CIT(E)] had rejected the applications, citing non-compliance with the document submission requirements under Rule 17A. Despite issuing multiple show cause notices, CIT(E) found that the trust failed to provide the necessary clarifications and supporting documents, leading to the rejection of its application for tax-exempt status under Section 12AB and the corresponding denial of approval under Section 80G.
Before ITAT, the trust argued that while some documents had been submitted, full compliance was hindered by unavoidable circumstances. The tribunal noted that the rejection was solely based on incomplete documentation and acknowledged the trust’s willingness to furnish the missing details. ITAT decided to set aside the CIT(E)’s order and remanded the matter for reconsideration. It directed CIT(E) to re-examine the applications based on merit, granting the trust a fair opportunity to submit the required documents. As a result, the appeal was allowed for statistical purposes, ensuring the trust could seek tax-exempt status after due compliance.
