Section 80G(5)(iii) Registration Disputes: 12 ITAT Rulings (July–August 2026)
12 ITAT rulings on Section 80G(5)(iii) approval disputes involving charitable trusts and foundations, pronounced July–August 2026. Research index for tax professionals.
This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) rulings pronounced between 23 July 2026 and 11 August 2026, all involving disputes over approval or registration under Section 80G(5)(iii) of the Income Tax Act, 1961. The cases span five ITAT benches — Jaipur, Pune, Jodhpur, Chennai, and Kolkata — and arise predominantly from applications filed by charitable trusts, foundations, and samitis in Form No. 10AB seeking regular approval under Section 80G(5), often in conjunction with registration under Section 12AB. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-ready reference to recent ITAT activity in the exemption-registration space.
Research index only. This page is a structured case-law reference compiled from tribunal records. It does not constitute legal advice, tax advice, or any form of professional opinion. Readers must verify all rulings against the original judgments and consult qualified professionals before acting on any information presented here.
The statutory framework in one paragraph
Section 80G of the Income Tax Act, 1961 provides for a deduction to donors making contributions to specified funds, institutions, and charitable entities. Section 80G(5) sets out the conditions that an entity must satisfy to be eligible for approval, entitling its donors to claim the deduction. Clause (iii) of Section 80G(5) — the central provision across all twelve rulings indexed here — requires that the institution or fund seeking approval must be one that is not expressed to be for the benefit of any particular religious community or caste, and must maintain regular accounts of its receipts and expenditures; the approval is granted by the Commissioner of Income Tax (Exemptions) upon application, currently filed electronically in Form No. 10AB under the amended scheme introduced by the Finance Act, 2020. The statutory framework links Section 80G(5)(iii) approval closely to registration under Section 12AB, because a valid registration under Section 12A / 12AB is typically a prerequisite for the grant of 80G approval, making simultaneous or sequential disputes over both registrations common before the Tribunal.
The 12 rulings
1. One World Trust Vasudhaiva vs CIT Exemption, Jaipur, Jaipur
- Bench: Income Tax Appellate Tribunal - Jaipur
- Date: 11 August 2026
- Sections engaged: 12A(1)(ac), 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The two appeals (ITA Nos. 330 & 329/JPR/2025) were filed by the assessee trust against separate orders both dated 22.12.2024 passed by the Commissioner of Income Tax (Exemption), Jaipur, denying registration under Section 12AB and under Section 80G(5). The assessee had filed an application in Form No. 10AB seeking registration under Section 12A(1)(ac) of the Act and for approval under Section 80G(5) of the Act; the appeal was heard on 04-08-2026 and the order was pronounced in open court on 11-08-2026, with the assessee unrepresented at the time of hearing.
2. Bhumi Foundation Wagholi,Wagholi vs CIT Exemption, Pune
- Bench: Income Tax Appellate Tribunal - Pune
- Date: 10 August 2026
- Sections engaged: 12A, 80G, 80G(5)(ii), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals (ITA 2345 & 2346/PUN/2026) were filed with a delay of 11 days; at the time of hearing, the assessee's authorised representative filed an affidavit seeking condonation of delay explaining sufficient cause, and the Tribunal condoned the delay and admitted the appeals, the departmental representative having raised no specific objection. The substantive dispute, per the source preview, concerns the brief facts arising from the assessee's registration and approval proceedings before the CIT (Exemption), Pune, touching on Sections 12A and 80G.
3. The Help Foundation,Jalore vs CIT Exemption, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 7 August 2026
- Sections engaged: 12A, 12A(1)(ac), 13(1)(c), 13(3), 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The assessee filed an online application on 30.11.2024 in Form No. 10AB seeking regular registration under Section 12A(1)(ac)(iii) of the Act; for the purpose of examining the application and verifying the genuineness of the assessee's activities, the CIT(E) issued a questionnaire dated 18.02.2025 requiring compliance by 05.03.2025. The assessee furnished a reply which the CIT(E) treated as only partial compliance, after which a show-cause notice was issued; the resulting proceedings culminated in the orders under challenge in ITA Nos. 646 and 647/Jodh/2025, which are the subject of these appeals before the Jodhpur Bench.
4. Smt Basanti Devi Foundation,Jodhpur vs CIT Exemption, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 6 August 2026
- Sections engaged: 10, 12A, 12A(1)(ac), 13(3), 7(2), 8(1), 80G, 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals (ITA Nos. 314 and 329/Jodh/2025) included a petition dated 25.03.2025 seeking condonation of a delay of 32 days in filing the appeal; the assessee stated that the orders rejecting its applications under Sections 12AB and 80G were sent to the e-mail address of Shri Saurabh Varshney, one of the directors of the assessee-company, who was suffering from cancer and passed away on 15.08.2024, on account of which information regarding the impugned orders was not available with the assessee. The assessee contended that it came to know about the impugned orders only subsequently, and the Jodhpur Bench heard the matter on 05-08-2026 before pronouncing the order on 06-08-2026.
5. Ravidas Samaj Mahasabha Samiti Sri vs Income Tax Officer, Bikaner
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 6 August 2026
- Sections engaged: 10, 12A, 12A(1)(ac), 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals (ITA Nos. 437 and 464/Jodh/2024, Assessment Year 2024-25) were filed by the assessee, which had sought registration under Section 12AB and approval under Section 80G(5)(iii), with the assessee's grounds specifically noting that its application for registration under the RPT Act 1959 was in process and that the next date of hearing was 28.05.2024, with the intention to file the certificate as soon as received to support its entitlement to 12AB registration as a prerequisite for 80G approval. The appeal was heard physically on 05-08-2026 and the order was pronounced on 06-08-2026.
6. Divine Blessings Charitable vs CIT(Exemption),, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 6 August 2026
- Sections engaged: 12A, 2(15), 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The consolidated appeals (ITA Nos. 498 and 499/Jodh/2023, Assessment Year 2023-24) arose from the rejection of the assessee's application for registration under Section 12AB and from the rejection of its connected application for approval under Section 80G; the source preview records a contribution of Rs. 2,00,000/- by cheque from Shri Shakti Singh on 24.11.2022 as part of the facts on record, and the ld. CIT's findings are referenced in the order. The appeals were heard on 03-08-2026 and the order was pronounced on 06-08-2026.
7. Shivay Jeevseva Foundation,Pali vs CIT Exemption, Jaipur, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 6 August 2026
- Sections engaged: 10, 12A, 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Both appeals (ITA No. 177/JODH/2024 and 357/JPR/2024) were filed with a delay of 114 days; the assessee filed separate petitions dated 21.03.2024 seeking condonation of delay, stating that the impugned orders were required to be challenged on or before 28.11.2023, whereas the appeals were filed on 21.03.2024. The assessee's stated ground for delay was a bona fide impression that, after rejection of its applications under Sections 12AB and 80G, it could submit fresh applications in Form No. 10AB rather than file appeals before the Tribunal.
8. Kheteshwar Gurukul Chhatrawas Samiti vs CIT Exemption, Jaipur, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 6 August 2026
- Sections engaged: 10, 12A, 12A(1)(ac), 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Four appeals were filed (ITA Nos. 945, 946, 948 & 949/Jodh/2024) covering distinct but related disputes: ITA No. 945/Jodh/2024 challenged the cancellation of provisional registration granted under clause (vi) of Section 12A(1)(ac); ITA No. 948/Jodh/2024 challenged the cancellation of provisional approval granted under clause (iv) of the first proviso to Section 80G(5); and ITA No. 949/Jodh/2024 challenged the rejection of the application for approval under Section 80G(5)(iii), with the matter heard on 04-08-2026 and the order pronounced on 06-08-2026.
9. Rakt Sevadal Sansthan Sayla vs CIT Exemption, Jaipur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 4 August 2026
- Sections engaged: 12A, 12A(1)(ac), 80G, 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Three appeals were filed (ITA Nos. 518, 520 and 521/Jodh/2024): ITA No. 518/Jodh/2024 challenged the rejection of regular registration under Section 12AB by order dated 31.03.2024; ITA No. 520/Jodh/2024 challenged the cancellation of provisional registration dated 27.05.2021 cancelled through the same order dated 31.03.2024; and ITA No. 521/Jodh/2024 challenged the rejection of regular approval and cancellation of provisional approval under Section 80G. A condonation of delay petition was also filed, and the order was pronounced in open court on 04-08-2026.
10. Likhmaram Sikshan Sansthan And Mali vs ITO, Ward - 3(1), Jodhpur
- Bench: Income Tax Appellate Tribunal - Jodhpur
- Date: 4 August 2026
- Sections engaged: 12A, 12A(1)(ac), 80G, 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: Four appeals were filed (ITA Nos. 480, 481, 482 and 483/Jodh/2024): ITA No. 480/Jodh/2024 challenged the rejection of regular registration under Section 12AB by order dated 26.02.2024; ITA No. 481/Jodh/2024 challenged the cancellation of provisional registration dated 17.11.2022 through the same order; ITA No. 482/Jodh/2024 challenged the rejection of regular approval under Section 80G(5)(iii) by order dated 26.02.2024; and ITA No. 483/Jodh/2024 challenged the cancellation of provisional approval dated 01.12.2022. A condonation of delay petition was also filed in these proceedings.
11. Ravikiran Foundation Of India,Chennai vs CIT, Exemptions,, Chennai
- Bench: Income Tax Appellate Tribunal - Chennai
- Date: 3 August 2026
- Sections engaged: 11, 12A, 12A(1)(ac), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeals (ITA Nos. 1462 & 1463/Chny/2025) arise out of separate orders both dated 22.03.2025 passed by the CIT (Exemptions), whereby the applications filed by the assessee in Form No. 10AB dated 30.09.2024 — seeking registration under Section 12AB read with Section 12A(1) — were disposed of adversely. The matter was heard on 01.07.2026 and the order was pronounced on 03.08.2026 by the Chennai 'A' Bench.
12. Kashipur Ma Sarada Mission vs The Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Kolkata
- Date: 23 July 2026
- Sections engaged: 80G(5), 80G(5)(iii)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: This appeal (ITA No. 1239/KOL/2026, Assessment Year 2027-28) was filed against the order of the Commissioner of Income Tax (Exemption), Kolkata, dated 25.03.2026, passed in respect of registration under Section 80G(5) of the Act. The CIT (Exemption) had initiated proceedings under Section 80G(5) after the assessee filed an application electronically on 30.09.2025 in Form No. 10AB seeking regular approval under Section 80G(5); the matter was heard on 13.07.2026 and the order was pronounced on 23.07.2026.
Patterns across these 12 rulings
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Simultaneous rejection of 12AB and 80G approval is the dominant fact pattern. Across the majority of these cases, CIT (Exemption) orders rejected both the Section 12AB registration application and the Section 80G(5) approval application through the same or related orders, requiring assessees to file multiple linked appeals before the Tribunal — frequently consolidated for hearing on the same date.
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Condonation of delay is a recurring procedural threshold. At least four of the twelve cases (Bhumi Foundation, Shivay Jeevseva Foundation, Rakt Sevadal Sansthan Sayla, and Likhmaram Sikshan Sansthan) involved formal petitions for condonation of delay in filing appeals, with causes ranging from a bona fide misunderstanding that fresh Form 10AB applications could be filed instead of pursuing appeals, to the death of a key director (Smt. Basanti Devi Foundation).
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Form No. 10AB is the uniform procedural vehicle. All cases where the application route is visible in the preview confirm that assessees filed electronically in Form No. 10AB — reflecting the post-Finance Act 2020 registration and re-registration regime uniformly applied across Jaipur, Jodhpur, Pune, Chennai, and Kolkata benches.
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Cancellation of provisional registrations alongside fresh application rejections. Several cases (notably Kheteshwar Gurukul Chhatrawas Samiti, Rakt Sevadal Sansthan Sayla, and Likhmaram Sikshan Sansthan) involve not just the rejection of a fresh regular registration application, but also the simultaneous cancellation of an earlier provisional registration or provisional approval, compounding the adverse impact on the assessee and resulting in multiple appeal numbers per assessee.
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Geographic concentration in Rajasthan-based CIT (Exemption) jurisdiction. Nine of the twelve rulings involve the CIT (Exemption), Jaipur, as respondent, with the bulk heard at the Jodhpur Bench. This geographic clustering may reflect a concentrated period of order-passing by that jurisdiction, and researchers tracking regional administrative patterns in exemption registrations may find this concentration significant.
How to use this compilation
This compilation functions as a first-pass research index, not a substitute for reading the full judgment text. Each case entry provides only the information available in the source preview and authoritative identity fields; the full operative portions, the Tribunal's substantive findings, and any directions or remands are contained in the complete order, which researchers must retrieve from the official tribunal portal or indiankanoon.org. The "Outcome not specified in source" designation for all twelve cases reflects that the dispositive result is not captured in the available text preview, and researchers must not infer an outcome — favourable or adverse — from the procedural facts described above.
When using this index for legal research, cross-check each ruling for subsequent developments: ITAT orders may be appealed to the relevant High Court under Section 260A, and High Court decisions may in turn be challenged before the Supreme Court. Stays, reversals, or affirmations at higher forums would change the precedential weight of any ruling listed here. Researchers should also verify whether the CBDT has issued any clarificatory circulars or instructions relevant to Section 80G(5)(iii) approval procedures that post-date or operate alongside the rulings cited.
For practitioners building arguments in similar disputes — particularly on condonation of delay or on the linkage between Section 12AB registration and Section 80G(5)(iii) approval — this index identifies the relevant ITA numbers and bench details to assist in sourcing the complete orders. Parallel CBDT instructions on Form 10AB processing timelines and CIT (Exemption) jurisdiction should be checked contemporaneously with any judgment-based research to ensure the regulatory context is current.
Source
All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.
Rangoli Bansal
Editorial Reviewer & CA Finalist
CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.
Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.
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