Trimurti Educational Charitable Trust vs. ITO, Exemption

Parties Involved

Facts Summary

The assessee, Trimurti Educational Charitable Trust, is a charitable trust engaged in educational and charitable activities. It is registered under section 12A of the Income Tax Act, 1961, and was granted provisional approval under section 80G(5) in Form No.10AC. The trust filed an application in Form No.10AB seeking regular approval under section 80G(5) on 28.03.2025. The Commissioner of Income Tax (Exemptions) rejected the application on the ground of delay in filing, without considering the merits. The assessee argued that the delay was due to a bona fide misunderstanding regarding the validity period of the provisional approval.…

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 in filing Form 10AB.
• 2. Whether the delay in filing the application was due to a bona fide and inadvertent mistake by the appellant.
• 3. Whether the principle of substantive justice over technicalities should be applied in this case.
• 4. Whether the appellant trust is otherwise eligible for the grant of final 80G approval.

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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