ITAT Remands Section 12A and 80G Registration Refusal: Holds Proposed Activities Sufficient for Approval

The Income Tax Appellate Tribunal (ITAT), Chandigarh Bench, has delivered a significant ruling in the case of Pooja Foundation Vs CIT (Exemptions), addressing the criteria for granting registration to charitable trusts. The Tribunal held that registration applications under Section 12A and Section 80G of the Income Tax Act 1961 cannot be summarily rejected merely because the applicant has not commenced substantial charitable activities at the time of filing.

The Bench emphasized that the registering authority is obligated to examine the genuineness of the trust's objects and the proposed activities, rather than solely focusing on past performance.

Case Background and The Dispute

The appeal arose from an order passed by the Commissioner of Income Tax (Exemptions) [CIT(E)], Chandigarh, dated 04.11.2025. The CIT(E) had rejected the assessee's applications for registration under Section 12A(a)(ac)(vi) and Section 80G of the Act.