Padmanabh Swami Math Dhulia Vs CIT (Exemptions) (ITAT Pune)
Purely Religious Activities Not ‘Charitable’: Worship-Centric Objects Fall Outside Charity: ITAT Pune Dismisses Appeal- Daily Pooja ≠ Charity: ITAT Confirms Cancellation of Provisional 12AB Registration
The Pune Bench “B” of the ITAT, vide order dated 01.01.2026 in Shri Padmanabh Swami Math Dhulia v. CIT (Exemptions), Pune (ITA No. 557/PUN/2025), dismissed the appeal and upheld rejection of regular registration u/s 12A(1)(ac) r.w.s. 12AB, along with cancellation of provisional registration earlier granted to the assessee trust.
The assessee trust had applied for regular registration claiming charitable status. However, the CIT(E), Pune rejected the application on the ground that the objects and activities of the trust were purely religious, revolving around worship of Shri Padmanabh Swami Samadhi, daily pooja and annual religious functions such as Datta Jayanti and Punyatithi. The trust failed to demonstrate that it carried out any independent charitable activities beyond its religious mandate, despite declaring itself as a charitable institution in Form 10AB.
The CIT(E) further noted that the assessee failed to furnish supporting evidence of activities, beneficiaries, dates and places of charitable work on the e-filing portal, as mandated. The claim that bills and vouchers were uploaded on Google Drive was rejected as procedurally invalid, and no verifiable documentary evidence was available on record to establish genuineness of activities.
Before the Tribunal, the assessee remained unrepresented on multiple hearing dates, and no material was produced to rebut the findings of the CIT(E). The ITAT observed that in absence of any contrary evidence, and considering that the activities were admittedly religious in nature, the CIT(E) was justified in concluding that the trust did not satisfy the statutory conditions of charitable nature and genuineness of activities required for registration u/s 12AB.
Accordingly, the ITAT affirmed the rejection of regular registration and cancellation of provisional registration, and dismissed the appeal.
FULL TEXT OF THE ORDER OF ITAT PUNE
