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Amrut Public Charitable Trust vs. ITO Exemption

Case No: ITA No. 7387/Mum/2025
Court: Income Tax Appellate Tribunal, 'A' Bench Mumbai
Date: 1/19/2026

Parties Involved

appellantAmrut Public Charitable Trust
respondentITO Exemption

Facts Summary

The assessee, Amrut Public Charitable Trust, is a charitable trust registered under the Bombay Public Trust Act, 1950, and is engaged in religious and charitable activities. The trust was granted registration under section 12A of the Income-tax Act, 1961, valid up to A.Y. 2026–27, and provisional approval under section 80G(5) in Form No. 10AC, valid up to A.Y. 2025–26. The assessee filed its application in Form No. 10AB on 28.03.2025 for regular approval under section 80G(5). The Commissioner of Income Tax (Exemptions) rejected the application due to a delay of more than 20 months in filing, holding that the delay rendered the application non-maintainable. The assessee appealed this decision, arguing that the delay was due to a bona fide misunderstanding regarding the validity period of the provisional approval.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the learned CIT(Exemption) erred in rejecting the appellant's application for final approval under Section 80G(5) solely on the technical ground of delay.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

3 precedents cited in this judgement.

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Amrut Public Charitable Trust vs. ITO Exemption | ITA No. 7387/Mum/2025 | 2026 | Opakhya