Jidnyasa Prabodhan Trust Vs CIT (ITAT Pune)
Summary: Jidnyasa Prabodhan Trust filed Form No. 10AB on 26.09.2025 seeking regular approval u/s 80G(5) of the Income-tax Act.
While making the online application, the Trust selected an incorrect statutory clause or sub-clause. The CIT (Exemption) found that the application did not conform to the clause applicable to the Trust’s case. The Trust was also stated not to have furnished a copy of the relevant regular approval in Form No. 10AC under the provision referred to in the application.
Treating the application as technically defective, the CIT (Exemption) rejected it by order dated 26.03.2026. The eligibility of the Trust for approval u/s 80G(5) was consequently not examined on merits.
Aggrieved by this rejection, the Trust approached the Pune Tribunal.
A Wrong Clause, Not a Wrong Claim
The Trust argued that the application had been rejected only because of an inadvertent error in selecting the applicable statutory sub-clause in Form 10AB.
According to the Trust, this was a procedural mistake, not a substantive defect affecting its eligibility for approval. The particulars necessary for considering the application were otherwise available. Merely clicking the wrong section code on the electronic portal should not result in rejection of the entire application or loss of the benefit otherwise available under the Act.
