Rajah Annamalaipuram Vs CIT (Exemptions) (ITAT Chennai)
The Chennai Bench of the Income Tax Appellate Tribunal examined two connected appeals filed by a temple trust concerning registration under Sections 12A and 12AB of the Income-tax Act, 1961.
The first appeal challenged an order dated 18.10.2022 passed by the Principal Commissioner of Income Tax (Exemptions)/CPC, which granted the trust provisional registration for three years from AY 2023-24, instead of registration for five years from AY 2022-23 to AY 2026-27. The second appeal arose from an ex parte order dated 03.06.2025, by which the Commissioner (Exemptions) rejected the trust’s application filed on 08.11.2024 in Form 10AB seeking regular registration under Section 12AB.
There were delays of 1035 days and 47 days respectively in filing the appeals. The assessee sought condonation, stating that it was an old temple trust registered under Section 12A since 1986 and had regularly claimed exemption under Section 11. Following the demise of its long-serving President in 2015, disputes arose regarding office-bearers, leading to litigation before the Madras High Court. Only after court intervention, appointment of a Judge Commissioner, and conduct of elections was the trust able to finalise accounts and pursue appellate remedies. The Tribunal, considering these circumstances and the long-standing nature of the trust, condoned both delays.
