IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND Ms. ASTHA CHANDRA, JUDICIAL MEMBER Shree Chaitanya-Ram Foundation CIT(Exemption), Pune Sarvanah Hills, Flat No.401, DSK Vs.

Ranwara Lane, Bavdhan, Pune – 411021 PAN: ABICS2444J (Appellant) (Respondent) Assessee by : Shri Nikhil S Pathak Department by : Shri Prashant Gadekar, CIT Date of hearing : 20-01-2026 Date of pronouncement : 21-01-2026

O R D E R

PER BENCH :

The above two appeals filed by the assessee are directed against the separate orders dated 09.09.2025 of the Ld. CIT(Exemption), Pune rejecting the application for grant of approval u/s 80G and registration u/s 12A of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) respectively. For the sake of convenience, both these appeals were heard together and are being disposed of by this common order.

2. First we take up ITA No.2619/PUN/2025. Facts of the case, in brief, are that the assessee filed an application in Form No.10AB on 27.03.2025 for registration of the trust under section 12A(1)(ac)(vi)-ITEM(b) of the Act. With a view to verify the genuineness of the activities of the assessee and compliance to requirements of any other law for the time being in force by the trust / institution as are material for the purpose of achieving its objects, a notice was issued through ITBA portal on 07.05.2025 requesting the assessee to upload certain information / clarification. In response to the same, the assessee filed certain details. From the various details furnished by the assessee the CIT(Exemption) noted that the details given by the assessee are very general in nature and no specific details as what actual activities were carried out are not submitted. No supporting credible evidences like bills / invoices were furnished. Further, the photographs furnished do not establish any charitable activities. He further noted that the assessee has filed the present application u/s 12(1)(ac)(vi)(B) of the Act. Again, there was delay in filing of the application. He, therefore, rejected the various submissions made by the assessee and rejected the application for grant of registration u/s 12A of the Act.

3. Since the CIT(Exemption) rejected the grant of registration u/s 12A of the Act and cancelled the provisional registration granted earlier, he rejected the application for grant of approval u/s 80G of the Act also.

4. Aggrieved with such order of CIT(Exemption), the assessee is in appeal before the Tribunal by raising the following grounds:

On the facts & circumstances of the case and in law, the learned CIT-Exemption erred -

(1) in holding that the assessee had failed to establish the genuineness of its charitable activities without appreciating the submissions by the assesse company:

(2) that on the facts and in the circumstances of the case and considering the principles of natural justice, the matter should be set aside to the file of the Assessing Officer to be decided afresh after considering the merits of the application and providing a fair opportunity to the appellant.

(3) It is therefore prayed that the Hon'ble ITAT may pleased to a. Quash the order of the learned CIT (E) dated 09/09/2025 b. Set aside the matter to the file of the Assessing Officer with a direction to re-adjudicate the application under Section 12AB after providing a reasonable opportunity to the appellant.

c. Pass any other order as Hon'ble Tribunal deems fit and proper in the interest of justice.

5. Similar grounds have been raised in ITA No.2618/PUN/2025 which read as under:

On the facts & circumstances of the case and in law, the learned CIT - Exemption erred (1) in rejecting the application for approval u/s 80G(5) citing the technical discrepancies in filing Form 10AB (2) in cancelling the provisional registration granted on 27/01/2023 citing the same reasons as per Ground No.1;

(3) that on the facts and in the circumstances of the case and considering the principles of natural justice, the matter sh