ITAT Chennai Ruling: Finance Act 2024 Amendment Salvages Section 80G Approval Despite Late Filing

In a significant development for charitable institutions, the Income Tax Appellate Tribunal (ITAT), Chennai Bench, has provided relief to a charitable trust whose application for approval under Section 80G was initially rejected on the grounds of delay. The Tribunal clarified the applicability of the amendments introduced by the Finance Act 2024, specifically regarding the timelines for filing applications.

The case in question, Siddhar Sri Balasubramania Swamigal Trust Vs CIT (Exemptions), highlights the transition from rigid filing deadlines to a more flexible regime for charitable entities seeking tax exemptions.

Factual Matrix of the Case

The dispute arose when the assessee-trust submitted an application for approval via Form No. 10AB. This application was filed under clause (iii) of the first proviso to sub-section (5) of Section 80G of the Income Tax Act 1961. The filing date was recorded as 31.03.2025.