##PAGE1##

आयकर अपीलीय अिधकरण ,चਔीगढ़ (cid:586)ायपीठ “A” , चਔीगढ़

IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH

BENCH “A”, CHANDIGARH

HEARING THROUGH: VIRTUAL MODE

঒ी लिलत कु मार, (cid:586)ाियक सद(cid:735) एवं ঒ी मनोज कु मार अঁवाल, लेखा सद(cid:735)

BEFORE: SHRI. LALIET KUMAR, JM &

SHRI. MANOJ KUMAR AGGARWAL, AM

आयकर अपील सं ITA No. 695 /Chd/2026

./

U/s 80G

Bhawani Shankar Anangpuria बनाम The CIT(Exemptions),

Charitable Trust, Chandigarh

Plot No. D2/20, Sector 10,

DLF Faridabad 121006

(cid:725)ायी लेखा सं PAN NO: AAATB7959F

./

अपीलाथ५ Appellant ঋ(cid:529)थ५ Respondent

/ /

&

आयकर अपील सं ITA No. 696 /Chd/2026

./

U/s 12AB(1)(b)(ii)

Bhawani Shankar Anangpuria बनाम The CIT(Exemptions),

Charitable Trust, Chandigarh

Plot No. D2/20, Sector 10,

DLF Faridabad 121006

(cid:725)ायी लेखा सं PAN NO: AAATB7959F

./

अपीलाथ५ Appellant ঋ(cid:529)थ५ Respondent

/ /

िनधा१ौरती की ओर से Assessee by : Sh. Akul Aggarwal, CA

/

राज(cid:738) की ओर से Revenue by : Smt. Jaishree Sharma, CIT DR

/

सुनवाई की तारीख Date of Hearing : 21.07.2026

/

उदघोषणा की तारीख Date of Pronouncement : 23.07.2026

/

आदेश Order

/

PER LALIET KUMAR, J.M:

The captioned appeals have been preferred by the assessee

against the separate orders each dated 16.03.2026 passed by the

2

695 & 696/Chd/2025

learned Commissioner of Income Tax (Exemptions), Chandigarh,

whereby the applications filed by the assessee in Form No.10AB

seeking registration were rejected.

2. Brief facts

2.1 The assessee is a charitable trust which filed separate

applications in Form No. 10AB seeking registration/ approval under

section 12AB / 80G of the Income-tax Act, 1961. The applications

were filed on 29.09.2025 before the learned CIT (Exemptions). During

the course of proceedings, the learned CIT(E) noticed certain

discrepancies in the application seeking registration and accordingly

issued a show cause notice requiring the assessee to furnish, inter

alia, a brief note and details on the charitable activities carried out

and documentary evidence substantiating the charitable activities

along with supporting books of account, vouchers and bank

statements.

2.2 The Ld. CIT(E) after examining the submissions of the Assessee

found that the explanations furnished by the Assessee are not

satisfactory. The Ld. CIT(A) found that the perusal of the trust deed

and details of trustees clearly shows that the entire control and

management of the trust vests with members of the founder’s family

and thus the Ld. CIT(A) considered it not a fit for registration s

3

695 & 696/Chd/2025

Charitable Institution and rejected the Application of the Assessee for

registration under section 12AB of the Act.

3. Submissions of the Learned Authorized Representative (AR)

3.1 In both the appeals and submissions of the Ld. AR that the

impugned orders have been passed without appreciating that the

dominant objects of the trust which are educational and charitable in

nature and the findings of the Ld. CIT(E) for rejection of the

registration stating no religious activities have been undertaken are

unsustainable. The Ld. AR submitted that the Assessee has a fair

case on merit and have requisite documents and record to prove its

case. It has further been submitted that the rejection by the Ld.

CIT(E) on conjectures and surmises without any cogent reason

regarding non-genuineness of the activities is totally unfair.

Similarly, it has been submitted by the Ld. AR that the findings of the

Ld. CIT(E) in ITA No. 695/Chd/2026 describing that in the absence of

any registration u/s 12AB, it does not meet the requirement for

approval as mandated by section 80G(5) of the Act and accordingly

denied the grant of approval u/s 80G without going into the merits of

the case. A request has therefore, been made to remand the matters

back to the CIT(E) for fresh adjudication in both the appeals.

4. Submissions of the Learned Departmental Representative (DR)

4

695 & 696/Chd/2025

4.1 The learned Departmental Representative relied upon the

findings recorded in the impugned orders and submitted that

sufficient opportunity had been af