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INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Suchitra Kamble, J, Makarand V. Mahaadekar, ACJ
SHRI UMEDKUMAR MANDIR TRUST NADIAD – Appellant
Versus
THE CIT(EXEMPTION) AHMEDABAD – Respondent
Headnote: Read headnote
आदेश/ORDER
PER MAKARAND V. MAHADEOKAR, AM:
This appeal is filed by the assessee against the order dated 14.12.2024 passed by the Commissioner of Income Tax (Exemption), Ahmedabad [hereinafter referred to as “CIT(E)”], rejecting the assessee’s application in Form No. 10AB for approval under section 80G(5)(iii) of the Income-tax Act, 1961[hereinafter referred to as “the Act”].
Facts of the Case
2. The assessee is a public charitable trust created by a trust deed dated 26.05.1905. The trust filed an application in Form No. 10AB on 28.06.2024 seeking approval under section 80G(5)(iii) of the Act. The trust had already been granted provisional approval from 31.05.2021, which was valid up to A.Y. 2024–25. During the course of proceedings, the Learned CIT(Exemption) issued a letter dated 17.09.2024 calling for details, which were furnished by the assessee vide reply dated 02.10.2024. Subsequently, a show cause notice dated 25.11.2024 was issued, wherein it was
The CIT(E) must conduct a thorough analysis of the trust's activities and supporting documentation to determine eligibility for approval under section 80G, rather than relying solely on a literal rea....
Approval under Section 80G cannot be denied based solely on alleged religious objectives when primarily charitable in nature.
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