Temporary Mosque Does Not Make Trust Religious, 12AB Rejection Set Aside

Hamza Welfare Trust Vs CIT (Exemptions) (ITAT Bangalore)

Assessee-trust applied for permanent registration u/s 12AB & approval u/s 80G. CIT(E) rejected application (27.12.2024), holding that Trust had not commenced substantial activities, only received donations & constructed a mosque building. Hence, assessee should file a fresh application as a religious trust, not charitable. Assessee appealed, explaining that it was in process of creating infrastructure for orphanages, health centres, schools etc. as per its objects.

Assessee’s Arguments

• Act

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