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Rajvee Foundation Vs. CIT(E)

Case No: ITA No.438/Ahd/2025
Court: Income Tax Appellate Tribunal, Ahmedabad
Date: 8/19/2025

Parties Involved

appellantRajvee Foundation
respondentThe Commissioner of Income Tax (Exemption), Ahmedabad

Facts Summary

The assessee, a trust registered under the Income-tax Act, 1961, filed an application in Form No. 10AB on 28.06.2024 seeking approval under section 80G(5) of the Act. The Commissioner of Income Tax (Exemption), Ahmedabad (CIT(E)) had earlier granted provisional approval under section 80G(5) vide order dated 22.04.2023, valid for Assessment Years 2023–24 to 2026–27. However, during the processing of the application, the CIT(E) observed that one of the objects of the trust refers to providing Dharmashala facilities for pilgrims, which the CIT(E) deemed religious in nature. Consequently, the CIT(E) issued show-cause notices on 12.12.2024. The assessee submitted certain compliances on 13.11.2024, but the CIT(E) found the explanations unsatisfactory. Therefore, the CIT(E) rejected the application and cancelled the provisional approval in an order dated 26.12.2024.

Decision in favour of

Assessee

Legal Issues

  • 1. Whether the assessee trust is eligible for approval under section 80G(5) of the Act.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

4 precedents cited in this judgement.

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Rajvee Foundation Vs. CIT(E) | ITA No.438/Ahd/2025 | 2025 | Opakhya