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2026 Supreme(Online)(ITAT) 4479

INCOME TAX APPELLATE TRIBUNAL (PUNE BENCH)
Manish Borad, Accountant Member, Astha Chandra, Judicial Member
Bhairavnath Mandir – Appellant
Versus
CIT Exemption, Pune – Respondent


Advocates:
For the Appellants/Petitioners: Shri B.C. Malakar
For the Respondents: Shri Amit Bobde

Table of Content
1. cit(e) rejected 80g approval for lack of pre-2021 registration. (Para 2 , 3)
2. assessee argued valid 12ab registration suffices for 80g. (Para 4 , 5 , 6)
3. dr supported rejection; tribunal reviewed facts. (Para 7 , 8)
4. precedents confirm approval with intact registration. (Para 9 , 10)
5. appeal allowed; direct 80g approval grant. (Para 11)

आदेश/ORDER

PER ASTHA CHANDRA, JM :

The appeal filed by the assessee is directed against the order dated 21.08.2025 of the Ld. Commissioner of Income Tax (Exemption), Pune [“CIT(E)”] whereby he rejected the application of the assessee filed before him on 21.03.2025 in Form No. 10AB under sub clause (B) of clause (iv) of first proviso to sub-section (5) of section 80G of the Income Tax Act, 1961 (the “Act”)

2. Briefly stated, the facts of the case are that the assessee is a public charitable trust registered under the Bombay Trust Act, 1950 since 1975. The assessee was granted provisional approval u/s 80G(5) of the Act from 24.05.2022. Thereafter, the assessee trust applied for regular approval/ registration in Form No. 10AB on 21.03.2025 under the provisions of section 80G(5)(iv)(B) of the Act. On receipt of the assessee’s applicat

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