Satyay Mataji Mandir Mangroliya Parivar Trust Vs CIT (Exemption) (ITAT Rajkot)
The assessee filed two appeals challenging separate orders of the Commissioner of Income-tax (Exemption), Ahmedabad, rejecting its application in Form 10AB under Section 12A(1)(ac)(vi) of the Income-tax Act, 1961 for registration under Section 12AB, and its application in Form 10AB under Section 80G(5)(iv)(B) dated 30.08.2024. The principal grievance in the appeal relating to Section 12AB was that the Commissioner rejected the registration application on the ground that the trust’s objects were restricted to the benefit of a particular religious community or caste rather than the public at large.
The assessee had filed Form 10AB on 19.02.2024. Pursuant to a notice dated 06.05.2024, it furnished certain details on 31.05.2024. On examining the trust constitution, the Commissioner observed that the trust’s objects were confined to members of the Mangrolia, Bhadkan, Vastani and Hirani families. A further show cause notice dated 05.08.2024 referred to the eligibility criteria for joining the trust and several objects which, according to the Commissioner, were intended for the benefit of those families, including celebration of religious festivals, construction and management of community halls, medical assistance, temple-related activities, youth programmes, assistance to economically weaker family members, welfare of women and students belonging to those families, and educational assistance. The Commissioner required the assessee to explain why there was no contravention of Section 12AB(4) read with Section 13(1)(b) and to furnish details of expenditure incurred on such activities.
